Comprehensive Double Taxation Agreement Number 10 – Switzerland
The Hong Kong Inland Revenue Department (“IRD”) continues its drive to conclude the magical 12 CDTAs required by the OECD in order for it to be taken off the watch-list of countries/jurisdictions with...
View ArticleLegislative Council Responds to Questions on Taxation
Professor K C Chan, Secretary for Financial Services and the Treasury, provided some interesting comments in his response to questions addressed to the Government. On May 5, Professor Chan advised that...
View ArticleTHE COMMISSIONER OF INLAND REVENUE IS REMINDED TO DETERMINE OBJECTIONS WITHIN...
Whilst the decision in Li & Fung (Trading) Limited and CIR (HCIA 1/2010) was a most welcome “win” for the taxpayer, in the Court of First Instance the case highlighted another problem that can...
View ArticleDOCTRINE OF “LEGITIMATE EXPECTATION” RELIANCE ON THE INLAND REVENUE...
The case of C.I.R. v CG Lighting Limited was never allowed to proceed to the Court of Final Appeal. Many issues arise from the conduct of this case, but the most galling, in my opinion, was the...
View ArticleWILL THE FINANCIAL SECRETARY LISTEN 2012-13 BUDGET
The 2012-13 Budget Speech is due to be delivered by the Financial Secretary, Mr John C Tang, on February 1st 2012. It will be interesting to note the extent to which the Financial Secretary has...
View ArticleHONG KONG BUDGET 2012-2013
Whether you are surprised or disappointed I expect that certain sectors of the community with definitely feel let down by the Financial Secretary (“the FS”). The FS announced a consolidated surplus of...
View ArticleHONG KONG TAX – THE OBLIGATION TO FILE A PROFITS TAX RETURN
During the past two months, the Inland Revenue Department (“the Department”) has sent out profits tax returns to companies that are known to be carrying on business in Hong Kong. The Department is...
View Article“CARRYING ON BUSINESS” – A HONG KONG DISCUSSION
As I stated in a previous article, profits derived by a person who does not carry on “a trade, profession or business in Hong Kong” will not be subject to Hong Kong profits tax, according to Section 14...
View ArticleHONG KONG BUDGET 2013-2014
John Tsang, the Financial Secretary (“FS”), will deliver his budget on 27th February 2013. In his 2012/2013 budget, the FS forecast a deficit of HK$(3.4bn) for 2013/2014, however it will come as no...
View ArticleHONG KONG BUDGET 2013/2014
Over the period 2002/2003 to 2011/2012, and particularly during the period of John Tsang’s stewardship of the Government’s finances, there has become an increasing reliance on revenue from land...
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