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Taxation Legislation

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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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 Treaties – Exchange of Information

March 25, 2010

On January 6, 2010, LegCo passed the Inland Revenue (Amendment) Ordinance 2010 (“the Amendment Ordinance”).  This has enabled Hong Kong to adopt the 2004 Organisation for Economic Cooperation’s (“OECD”) version of the Exchange of Information Article in its comprehensive double taxation treaties with other jurisdictions.  The amendments to the Inland Revenue [...]

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Double Taxation Agreements

March 19, 2010

The Inland Revenue Department continues to be very active in its Double Taxation Relief negotiations with other countries.  In 2009, negotiations took place with the following countries:
France (3rd round)
Indonesia (1st round)
Ireland (1st round)
Spain (1st round)
UAE (1st round)
The United Kingdom (2nd round)
And in the first few months of 2010 there have [...]

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Is The Government Listening?

March 19, 2010

Before the Financial Secretary issued the 2010/2011 budget on February 24, 2010, he had asked the business community, as well as other interested parties, to submit their “budget wish list” to him.  Among the organisations that responded were:

The Hong Kong General Chamber of Commerce (“HKGCC”)
The British [...]

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