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.
On 22 February 2017, the Financial Secretary of the Hong Kong Special Administrative Region (“Hong Kong”), announced the Budget for the fiscal year 2017-18. According to this Budget, the fiscal year 2016-17 is likely to have a surplus of HK$ 92.8 billion, which significantly exceeds the original estimated amount of HK$ 11 billion, largely due […]
Trust & Company Service Providers (“TCSP’s”) in Hong Kong would require a license issued by the Registrar of Companies in Hong Kong.