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Hong Kong/United Kingdom and Ireland Comprehensive Double Taxation Agreements – Update

by Roddy Sage on July 5, 2010

in Taxation Legislation

Hong Kong has signed Comprehensive Double Taxation Agreements (“CDTAs”) with the United Kingdom and Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.  So far in 2010, Hong Kong has signed eight agreements, which all adopt the 2004 OECD standard on [...]

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Hong Kong and Ireland Sign a Comprehensive Double Taxation Agreement

by Roddy Sage on June 24, 2010

in Taxation Legislation

Hong Kong signed a Comprehensive Double Taxation Agreement (“CDTA”) with Ireland on June 22, 2010.  This is Hong Kong’s 13th CDTA.
Secretary for Financial Services & the Treasury, Professor Chan commented that “the agreement will encourage Hong Kong enterprises to leverage on the success of Irish companies in the [...]

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Hong Kong / United Kingdom Comprehensive Double Taxation Agreement

June 23, 2010

Hong Kong’s Comprehensive Double Taxation Agreement (“CDTA”) with the United Kingdom was signed on June 21, 2010.  It is Hong Kong’s 12th CDTA.
Under the CDTA, dividends paid by a company will be exempt from tax, and dividends paid by a UK Real Estate Investment Trust will be subject to [...]

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Hong Kong Issues Guidelines on the Exchange of Tax Information

June 22, 2010

On June 9, 2010, the Inland Revenue Department (“the Department”) published its Departmental Interpretation and Practice Note No 47 “Exchange of Information under Comprehensive Double Taxation Agreements”. Although, as I have previously noted, the Department does not feel bound by its own Practice Notes, they nonetheless provide genuine guidance as to the normal Departmental [...]

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Hong Kong / Austria CDTA – Double Taxation Treaty Update

June 22, 2010

Hong Kong concluded a Comprehensive Double Taxation Agreement (“CDTA”) with Austria on May 25, 2010.  This is Hong Kong’s 11th CDTA, and provides for the reduction of withholding tax on dividends to 0% if the beneficial owner is a company that directly holds at least 10% of the capital of the [...]

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Offshore Manufacturing – The Saga Continues – C.I.R v CG Lighting Limited

June 9, 2010

Fok J’s decision in the case of the Commissioner of Inland Revenue v CG Lighting Limited, heard before the Court of First Instance (Inland Revenue Appeal NO.8 of 2009 on Appeal from B/R 92 of 2007), provides an interesting insight into the attitude of the Inland Revenue Department (“the Department”) and [...]

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Offshore Manufacturing Profits – The Commissioner smiles, but for how long?

May 18, 2010

The Hon Fok J upheld the appeal by the Commissioner of Inland Revenue (“the Commissioner”) to the Court of First Instance in the case of Commissioner of Inland Revenue v CG Lighting Limited (HCIA8/2009).
I suspect that Mr Yu, SC, leading counsel for the Commissioner, was as surprised as anyone to have succeeded [...]

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Legislative Council Responds to Questions on Taxation

May 17, 2010

Professor K C Chan, Secretary for Financial Services and the Treasury, provided some interesting comments in his response to questions addressed to the Government.
On May 5, Professor Chan advised that revenue collections by the Inland Revenue Department from Salaries Tax and Profits Tax were estimated to be $179.1 billion, 6% less [...]

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Hong Kong Concludes Two More CDTAs

May 17, 2010

The Inland Revenue Department signed comprehensive double taxation agreements with Hungary and Kuwait on May 13, 2010.  This takes to 10 the number of comprehensive double taxation agreements that Hong Kong has signed.  With agreements having been reached with a number of other countries, including Austria, France, Ireland, Japan, Switzerland [...]

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Comprehensive Double Taxation Agreement Number 10 – Switzerland

April 20, 2010

The Hong Kong Inland Revenue Department (“IRD”) continues its drive to conclude the magical 12 CDTAs required by the OECD in order for it to be taken off the watch-list of countries/jurisdictions with unacceptable exchange-of-information policies.  On April 15, 2010, the IRD stated on its website:
“On 15 April 2010, Hong Kong [...]

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