As from 1 January 2018, Mainland China has introduced its first environmental tax law, the Environmental Protection Tax (the “EPT”) law. The EPT replaces the existing pollutant discharge fee (“PDF”) system, which was in operation for nearly the last 40 years. The main difference between the PDF and the EPT is that the former is […]
On 21 December 2017, the Chinese central government authorities issued a tax circular Caishui [2017] No. 88 (“Circular 88”) on China investment profits by foreign investors. According to Circular 88 and subject to conditions discussed below, foreign investors are allowed to defer payment of withholding tax on dividend income from equity investments in Chinese resident […]
Whether enough tax substance in a Trust is present will always depend on the relevant facts of the case.
Pursuant to the general charging provision of Section 14(1) of the Inland Revenue Ordinance (‘HK-IRO’), an income is NOT liable to profits tax (corporate income tax) if it is (i) not derived from a trade, profession or business carrying on in Hong Kong and/or (ii) not arising in or derived from Hong Kong (i.e. sourced […]
