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Locality of Profits

January 13, 2010

In December 2009, the Inland Revenue Department published the revised Departmental Interpretation and Practice Note No.21 (Revised) – “Locality of Profits”.
The determination of the location of a source of a given profit has caused some disputes between taxpayers and the Inland Revenue Department.  It is clear that the source of a profit is “what the [...]

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Misled By The Inland Revenue Department?

November 18, 2009

When I arrived in Hong Kong in the early 1980’s obtaining a copy of the Inland Revenue Department’s Assessor’s Manual was considered essential, but extremely difficult to acquire.  Gradually the Assessor’s Manual has been replaced by a series of Departmental Interpretation and Practice Notes (DIPNs).  Whereas the Assessor’s Manual had [...]

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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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US tax snoops zero in on Hong Kong? Let’s be realistic.

September 28, 2009

Nick Westra’s article in this week’s Sunday Morning Post (September 27th, 2009) must have pleased the IRS.  If anything is going to raise concern amongst US citizens living in Hong Kong it is exactly this type of suggestion that a foreign authority will have unrestricted access to information.  The article appears to ignore the fact [...]

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Expat trapped in Hong Kong

September 25, 2009

Is it time for Hong Kong to overhaul its tax collection methods? Multi million dollar losses suggest it is.

The article, ‘Expat Trapped in Hong Kong over unpaid tax bill’ that appeared in last week’s issue of The Sunday Morning Post highlighted an interesting problem for the Hong Kong Inland Revenue Department.
The piece tells the story [...]

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A Step Forward

July 6, 2009

Over the past 12 months there have been numerous debates as to whether Hong Kong should enter into comprehensive double taxation agreements (CDTA) with its major trading partners.
In simple terms a CDTA is an agreement that limits the circumstances when a source of income may be taxed in both jurisdictions participating in the agreement. This [...]

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The Cost of A Tax Appeal – The IRD Knows It!

July 6, 2009

Hong Kong’s objection and appeal procedures against tax assessments raised by the Inland Revenue Department (“the Department”) can be costly should a taxpayer wish to pursue his right of objection.
Firstly, if a taxpayer wishes to appeal against an assessment, he may be required to purchase a tax reserve certificate (“TRC’s”). Notwithstanding that it is estimated [...]

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Hong Kong is NOT a Tax Haven

April 20, 2009

The Government has clearly stated that it will enact legislation to amend the Inland Revenue Ordinance in order to allow the Inland Revenue Department to share information with overseas tax authorities, in other words acceding to the demands of the Organisation for Economic Co-operation and Development (OECD) to sign up to international agreements facilitating tax [...]

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The fight for offshore profits claims continues

April 14, 2009

For many years Hong Kong manufacturing companies have taken advantage of the considerably lower labour costs in other Asian countries, particularly Mainland China.  Inevitably the nature of these arrangements varies but a large number of enterprises have established their own manufacturing/assembly plants in Mainland China.
Structured correctly, such arrangements may also reduce the tax burden of [...]

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Can a taxpayer rely on the Inland Revenue Department?

March 30, 2009

For many years taxpayers have relied on the Inland Revenue Department’s Departmental Interpretation Practice Notes (“DIPN”). Indeed, these have proved to be extremely helpful and have frequently assisted taxpayers understand how the provisions of the Inland Revenue Ordinance are to be interpreted. However, on the front of each DIPN it is stated that;
“These notes are [...]

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