The Hong Kong government plans to introduce a new tax scheme called the Tax Certainty Enhancement Scheme (“the Enhancement Scheme”), to enhance Hong Kong’s attractiveness as an international investment and business hub.
One of the most disputed areas is regarding source or taxability of income and offshore claims.
With an advance ruling, you can confidently plan their transactions with the assurance that the tax treatment has been agreed in advance and to avoid tax disputes.
It is sometimes argued that a company incorporated under HK Law (“HK Co”) will (a) automatically be regarded as a Hong Kong tax resident; and (b) only be subject to corporate tax in Hong Kong but not in other tax jurisdictions. However, one has to be well aware that if HK Co lacks (has insufficient) ‘tax […]
