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. […]

retirement in Thailand - HKWJ Tax Law

Retirement in Thailand for Dutch Nationals

When thinking about retiring, many Dutch nationals think about retirement to Thailand or some other exotic country to enjoy their golden years. This may incur in some issue with the Dutch tax authorities. Is retirement to these jurisdictions possible or even beneficial? Dutch Retirement Pension Taxation It is commonly known that Tax Authorities often provide […]

intellectual property tax planning - HKWJ Tax Law

Intellectual Property Tax Implications & Planning

The Organisation for Economic Co-operation and Development (OECD) and the G20 decided to address intellectual property taxation within the Base Erosion and Profit Shifting project by means of discussing appropriate transfer pricing rules. One has, therefore, to be aware of the potential intellectual property tax risks and challenges that could be made by the tax […]

tax implication of COVid 19 restrictions - HKWJ Tax Law

COVID-19 Tax Guidance Update on Tax Treaties

Last April 2020, the Organisation for Economic Co-operation and Development (“OECD”) issued the ‘OECD Secretariat Analysis of Tax Treaties and the Impact of the COVID-19 Crisis’ (“the Analysis”). The Analysis  is a practical COVID-19 tax guidance. It provides governments around the world with guidelines on how to treat unintended or adverse tax consequences that taxpayers […]