Tax Disputes & Investigations
There is a unit in the Hong Kong Inland Revenue Department (IRD) specialised in tax audit and investigations. They do in-depth review and investigations on cases selected. The selected taxpayers will likely have to spend a lot of time and manpower on dealing with the tax audit investigation.
We provide professional assistance to clients who are selected for tax audit. We also help to plan a proper strategy to reduce the tax and/or penalty (if any) as much as possible for clients. We can assist in attending interviews with the IRD, handling tax enquiries from the IRD, preparing and filing settlement proposals to the IRD.
Contact us to learn more about our services
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Transfer Pricing15 January 2021
Transfer pricing (“TP”) refers to the setting of prices for transactions of goods, services and intangible property between associated enterprises. Globalisation has increased the number of cross-border transactions between associated enterprises. This has also created opportunities for cross-border tax avoidance by taking advantage of differences in tax regimes across jurisdictions. This problem is commonly referred… read more
Tax Substance in Hong Kong5 January 2021
It is sometimes argued that a company incorporated under HK Law (“HK Co”) will (a) automatically be regarded as a Hong Kong tax resident for tax purpose; and (b) only be subject to profits tax in Hong Kong but not in other tax jurisdictions. However, one has to be well aware that if HK Co lacks… read more
Hong Kong General Anti-Avoidance Rules
What are they? Are they really dangerous? The more SAAR, the less GAAR? In Hong Kong, we are somehow in the very ‘luxurious’ position not to have only 1 General Anti-Avoidance Rule provision (“GAAR”), but even to have 2 GAAR provisions. The first GAAR provision can be found in section 61 of the Hong Kong… read more
Advance Rulings in Hong Kong28 December 2020
Why you may want Advance Rulings on Tax? Advance rulings on tax, a kind of tax insurance, help to reduce the tax risks companies may face. This, as for most investors and their management, potential tax liabilities and tax risks that may arise within the company remains a concern when conducting their businesses. As… read more