When however collecting this information for the purpose of acquiring a certification of residence status for the Hong Kong company under the Hong Kong – Spain double taxation treaty, the obtained information is likely to be ignored by the HK IRD as it is irrelevant for the application of the relevant double taxation treaty.
As from the year of assessment 2014/2015, i.e. as from April 1st 2014, Hong Kong will have 28 unlimited double taxation treaties effectively in place (with Austria, Belgium, Brunei, Canada, Czech Republic, France, Guernsey, Hungary, Indonesia, Ireland, Japan, Jersey, Kuwait, Liechtenstein, Luxembourg, Mainland China, Malaysia, Malta, Mexico, the Netherlands, New Zealand, Portugal, Qatar, Spain, Switzerland, […]
On 29th of March 2012, the Hong Kong Inland Revenue Department (‘Inland Revenue’) finally released its Advance Pricing Arrangement (‘APA’) procedures in its Departmental Interpretation and Practice Notes no 48 (‘DIPN 48’). According to paragraph 1 of DIPN 48, the DIPN will provide guidance for companies willing to conclude an APA and explains its process, […]
The question whether or not the profits including commissions arising out of securities and commodities trading are subject to Hong Kong corporate income tax have been subject to several Hong Court cases. In Nice Cheer Investment Limited v CIR (HCIA 8/2007), dated 28th of June 2011, were however the unrealised gains arising out of the […]