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 […]
The Organisation of Economic Cooperation and Development (“OECD”) is currently working on a new digital taxation proposal to further address the Base Erosion and Profits Shifting (“BEPS”) project, which is also commonly known as “BEPS 2.0”. BEPS 2.0 has two components, namely Pillar One and Pillar Two. Pillar Two (i.e. the imposition of a global […]
