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DIPN 21

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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Source of Profits – DIPN 21 Needs Amendment

October 22, 2009

Disagreements between the Inland Revenue Department (“the Department”) and taxpayers as to whether a particular source of profit accruing to a business carried on in Hong Kong is derived from Hong Kong, and therefore taxable, arise all to frequently. It would be foolish to believe that this uncertainty is ignored by persons contemplating establishing [...]

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