On 29th of March 2012, the Hong Kong Inland Revenue Department (‘Inland Revenue’) finally released its Advance Pricing Arrangement (‘APA’) procedures in its Departmental Interpretation and Practice Notes no 48 (‘DIPN 48’). According to paragraph 1 of DIPN 48, the DIPN will provide guidance for companies willing to conclude an APA and explains its process, […]
The question whether or not the profits including commissions arising out of securities and commodities trading are subject to Hong Kong corporate income tax have been subject to several Hong Court cases. In Nice Cheer Investment Limited v CIR (HCIA 8/2007), dated 28th of June 2011, were however the unrealised gains arising out of the […]
Guoshuihan [2009] No. 698 (“Circular 698”) was issued on the 10th of December 2009 and is still subject to considerable controversy, mainly because of its lack of clarity regarding non-residents of Mainland China. Some guidelines on the application of Circular 698 can be derived from Guo Shui Fa [2010] No 75 (“Circular 75”), which contains […]
