The Organisation for Economic Co-operation and Development (OECD) and the G20 decided to address intellectual property taxation within the Base Erosion and Profit Shifting project by means of discussing appropriate transfer pricing rules. One has, therefore, to be aware of the potential intellectual property tax risks and challenges that could be made by the tax […]
Last April 2020, the Organisation for Economic Co-operation and Development (“OECD”) issued the ‘OECD Secretariat Analysis of Tax Treaties and the Impact of the COVID-19 Crisis’ (“the Analysis”). The Analysis is a practical COVID-19 tax guidance. It provides governments around the world with guidelines on how to treat unintended or adverse tax consequences that taxpayers […]
In Hong Kong, we are somehow in the very ‘luxurious’ position not to have only 1 General Anti-Avoidance Rule provision (“GAAR”), but even to have 2 GAAR provisions. The first GAAR provision can be found in section 61 of the Hong Kong Inland Revenue Ordinance (“IRO”), and the second GAAR provision in section 61A of […]
On 4 November 2016, the Hong Kong SAR Government (‘the Government’) proposed a stamp duty increment. This increased the previous Scale 1 rates (i.e. ranged from 1.5% to 8.5%) on ad valorem stamp duty (‘AVD’) in respect of residential properties to a flat rate of 15%, for the purpose of combating the speculative activities in […]
