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From the yearly archives:

2010

The IRD Continues its Fight against Hong Kong Manufacturers

December 21, 2010

Earlier this year, at the request of the Financial Services and the Treasury Bureau, the Joint Liaison Committee on Taxation (JLCT) submitted a proposal to the Hong Kong Government to amend the Inland Revenue Ordinance (“IRO”) so as to allow Hong Kong taxpayers a profit tax deduction for plant and equipment used, free of charge, [...]

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Offshore Profits – Re-invoicing Trough Hong Kong

October 26, 2010

The change in practice by the Inland Revenue Department (“the Department”) regarding the assessment of profits booked in a re-invoicing vehicle located in Hong Kong continues to be a cause for concern.
Paragraph 27 of the Departmental Interpretation and Practice Notes No.21 (Revised), dated December 2009 (“DIPN”), clearly states that it is [...]

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2011-2012 BUDGET SUBMISSIONS

October 7, 2010

We are rapidly approaching the time of year when the various professional bodies, chambers of commerce, business associations etc. need to consider the content of their submissions to the Financial Secretary, The Hon John Tsang Chun-wah, on the Government’s budget for the fiscal year 2011-12.
Having been involved in this process [...]

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

July 5, 2010

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

June 24, 2010

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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