economix tax substance - HKWJ Tax Law

The Importance of Corporate Tax Substance

In Board of Review/Tax Tribunal Case X66, several appellants brought appeals to the Board of Review (“BoR”) under section 66 of the Hong Kong Inland Revenue Ordinance (“HK IRO”). For easy reading, Case X66 described below has been limited to one appellant only but this case shows similar points regarding the importance of tax substance. […]

Tax substance - HKWJ Tax Law

Tax Substance in Hong Kong

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 […]