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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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