From the monthly archives:

June 2010

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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