Tax publications
You will find here our tax publications (newsletters, special reports, etc.).
Hong Kong tax newsletters
Mazars’ comments on Hong Kong tax issues.
- September 2020 - Final OECD transfer pricing guidelines on financial transactions (part I: intra-group loans)
- September 2014 -Tax information exchange agreements between Hong Kong and 6 Nordic countries
- October 2023 - The Inland Revenue Bill for expanding the FSIE regime to cover asset disposal gains is published
- October 2023 - Stamp Duty Changes in the Policy Address 2023
- October 2023 - Bill for Tax Certainty for Onshore Disposal Gain of Equity Interests
- October 2020 - Final OECD transfer pricing guidelines on financial transactions (part II: treasury functions)
- October 2018 - New tax measures proposed in 2018 Hong Kong Policy Address
- October 2017 - Two-tier Tax Systems for SMEs and New Incentives for Innovation and Technology Sector
- October 2015 - Taxability of License Fees Under Deeming Provision
- October 2014 - Automatic exchange of financial account information in tax matters
- November 2022 - Bill on the proposed refined foreign source income exemption regime (“FSIE Regime”)
- November 2020 - Abolition of the Doubled Stamp Duty (DSD) on non-residential property
- November 2017 - IRD’s Practice Note on Taxation of Aircraft Leasing Activities
- November 2014 - Shanghai-Hong Kong Stock Connect Programme
- May 2018 - Enhanced Deduction for R&D Expenditures Introduced in Hong Kong
- May 2015 - Comprehensive Double Taxation Agreements with South Africa and United Arab Emirates
- May 2014 - Double stamp duty to be relaxed
- March 2022 – The EU grey list – What does it mean for Hong Kong businesses
- March 2021 - The OECD’s updated position on permanent establishment and residency due to COVID-19 pandemic
- March 2020 - An interim review of the economic substance rules in Bermuda, the Cayman islands and the BVI
- March 2018 - Hong Kong Issued Draft Legislation on Implementation of BEPS Action Plans
- March 2017 - New Tax Regime for Aircraft Leasing Market
- March 2015 - Court of final appeal ruled that taxpayer's right should be protected under the six-year limitation
- Mar. 2014 - First TIEA signed by Hong Kong
- June 2020 - Revised DIPN 39 on digital economy, electronic commerce and digital assets
- June 2014 - Court of First Instance ruled on taxpayer’s rights to correct errors
- July 2022 - Proposed changes to the offshore regime for passive income in Hong Kong
- July 2021 - Changes are around the corner: The BEPS 2.0 Pillar 2 update
- July 2019 - Economic Substance in Bermuda, the Cayman Islands and the BVI – Understanding the Requirements
- July 2018 - The Transfer Pricing and BEPS Legislation Passed in Hong Kong
- July 2017 - Hong Kong Becoming a Signatory to the Multilateral Instrument
- July 2014 - Comprehensive taxation agreement with Korea
- January 2021 - Changes are around the corner: the BEPS 2.0 Pillar 1 update
- January 2018 - Introduction of Two-Tier Profits Tax Rates System in Hong Kong
- January 2016 - Interim Tax Measures for Court-Free Amalgamation
- Jan. 2014 - Mazars' budget proposal 2014-2015
- Jan 2019 - Country-by-Country Reporting in HK
- Hong Kong Budget 2022-23
- Hong Kong Budget 2014 / 2015
- Hong Kong Budget 2014 / 2015
- February 2021 - OECD Guidance on transfer pricing implications of COVID-19
- February 2019 - Inland Revenue (Profits Tax Exemption for Funds) Amendment Bill 2018
- February 2018 - Hong Kong to Introduce Transfer Pricing Legislation
- February 2017 - The new Ad Valorem Duty (“AVD”)
- Feb. 2014 - Tax concession to promote Hong Kong as a potential domicile for captives
- December 2020 - E-form with information on TP documentation
- December 2019 - Transfer Pricing In Hong Kong - Departmental Interpretation and Practice Notes
- December 2015 - Hong Kong Proposes To Provide Tax Incentives for Corporate Treasury Centres
- December 2014 - XXX
- Comprehensive Double Taxation Agreements (CDTA)
- August 2021 - Tax treatments for corporate amalgamation under the court-free procedures
- August 2021 - Statement on a two-pillar solution to address the tax challenges arising from the digitalization of the economy
- August 2017 - Hong Kong Releases Consultation Report on BEPS Legislation
- April 2020-Transfer pricing in the wake of COVID-19 and the recent China-US trade dispute
- April 2020 - Hong Kong issued advance ruling on interpretation of permanent establishment
- April 2018 - Hong Kong Enacted Legislation For a Two-tiered Profits Tax Rates Regime
- April 2018 (Issue No. 2) - Comprehensive Double Taxation Agreement with India
- April 2015 - Hong Kong proposes to extend offshore funds tax exemption to private equity
- 2012-2013 Hong Kong Tax Newsletters
- 2010-2011 Hong Kong Tax Newsletters
- 2008-2009 Hong Kong Tax Newsletters
China tax newsletters
Mazars’ comments on tax issues in the People’s Republic of China.
- 2008-2012 China Tax Newsletters
- Nov. 2013 - Detailed implementation rules for filing of exemption on VAT-able cross-border services in Shanghai
- Dec. 2013 - Detailed implementation rules for filing of exemption on VAT-able cross-border services in Beijing
- May 2013 - New tax treaty between the Netherlands and China
- Dec. 2013 - Further expansion of scope of the PRC value added tax (“VAT”) reform
- Apr. 2014 - New tax treaty between China and France signed in 2013
- May 2014 - New tax treaty between China and Germany
- June 2014 - New China-UK tax treaty enters into force
- September 2014 - SAT initiates the anti-avoidance review of payments to overseas
- January 2015 - Easing of tax treatment in corporate restructuring activities in China
- February 2015 - Fine-Tuning of rules on non-resident indirect transfer by SAT
- February 2015 - China's major policy for overseas international taxation
- April 2015 - China Making further scrutiny on payments to overseas related parties
- April 2015 - Mainland and the HK SAR signed the fourth protocol to the arrangement for avoidance of double taxation
- July 2016 SAT Issued new rules on reporting of related party transactions and contemporaneous documentation
- March 2017-Chinese Government Authorized Local Governments To Formulate And Issue Preferential Policies On Business And Investment
- May 2017 - SAT Integrating BEPS Action Plans 8 to 10 and Action Plan 14
- July 2017 - Common Reporting Standards – AEOI Standard/CRS in China
- August 2017 - China Signs the Multilateral Instrument, Important Step for the Implementation of BEPS Action Plans
- August 2017 (No.2) - New Policies For Encouraging Foreign Investment In China
- September 2017 - A Recent Individual Income Tax Case Relating To Expatriates In China
- December 2017 - New Rules On The Timing Of Withholding Tax On Payments To Non-Residents
- January 2018 - Withholding Tax (“WHT”) Deferral for Foreign Re-investment in China
- February 2018 - Beneficial Ownership – Further Guidance From China Tax Authority
- April 2018 - The PRC SAT issued Public Note 11 to update interpretations of tax treaty articles
- September 2018 - The PRC Law on Individual Income Tax (“IIT”) Amendments Approved
- November 2018 - 5-Year Rule Under the New Individual Income Tax Law – Exposure Draft of the “Implementation Rules”
- January 2019 - PRC Individual Income Tax Implementation Rules and related Circulars finalized
- March 2019 - VAT rates are falling from 1 April 2019
- 2019年4月 - 增值税改革有关变化和影响
- April 2019 - More Interpretations on Individual Income Tax for Expatriates
- 2019年4月 - 外籍人士个人所得税新政详解
- May 2019 - China Adopts E-commerce Law – Its Tax Implications
- August 2019-Tax incentives provided to improve talent mobility in the greater bay area
- October 2019 - Incentives Given - The Greater Bay Area
- February 2020 - China's New Foreign Investment Law and Its Impact on Foreign Investment Enterprises
- February 2020 - New Measures for Claiming Treaty benefits
- April 2020-Transfer pricing in the wake of COVID-19 and the recent China-US trade dispute
- April 2020 - OECD secretariat analysis of tax treaties and the impact of the COVID-19 crisis
- September 2020 - China addresses permanent establishment and residency issues due to COVID-19
- January 2021 - Changes are around the corner: the BEPS 2.0 Pillar 1 update
- February 2021 - OECD Guidance on transfer pricing implications of COVID-19
- March 2021 - The OECD’s updated position on permanent establishment and residency due to COVID-19 pandemic
- July 2021 - Changes are around the corner: The BEPS 2.0 Pillar 2 update
- August 2021 - Statement on a two-pillar solution to address the tax challenges arising from the digitalization of the economy
- April 2022 - Latest development of APA in China Part I - Simplified procedures of unilateral APA
- May 2022 - Latest development of APA in China Part II - 2020 APA Annual Report and MAP Review Report
Transfer pricing
Mazars' comments on Transfer Pricing issues
- “Implementation measures of special tax adjustments” released by SAT for public consultation
- July 2016 - SAT Issued new rules on reporting of related party transactions and contemporaneous documentation
- May 2017 - SAT Integrating BEPS Action Plans 8 to 10 and Action Plan 14
- August 2017 - Hong Kong Releases Consultation Report on BEPS Legislation
- February 2018 - Hong Kong to Introduce Transfer Pricing Legislation
- July 2018 - The Transfer Pricing and BEPS Legislation Passed in Hong Kong
- Mazars Transfer Pricing Services in Asia
- January 2019 - Country-by-Country Reporting in Hong Kong
- Annual Review: Transfer Pricing 2019
- December 2019 - Transfer Pricing In Hong Kong - Departmental Interpretation and Practice Notes
- April 2020 - Hong Kong issued advance ruling on interpretation of permanent establishment
- April 2020 - Transfer pricing in the wake of COVID-19 and the recent China-US trade dispute
- September 2020 - Final OECD transfer pricing guidelines on financial transactions (part I: intra-group loans)
- October 2020 - Final OECD transfer pricing guidelines on financial transactions (part II: treasury functions)
- December 2020 - E-form with information on TP documentation
- January 2021 - Changes are around the corner: the BEPS 2.0 Pillar 1 update
- February 2021 - OECD Guidance on transfer pricing implications of COVID-19
- July 2021 - Changes are around the corner: The BEPS 2.0 Pillar 2 update
- August 2021 - Statement on a two-pillar solution to address the tax challenges arising from the digitalization of the economy
- April 2022 - Latest development of APA in China Part I - Simplified procedures of unilateral APA
- May 2022 - Latest development of APA in China Part II - 2020 APA Annual Report and MAP Review Report
Hong Kong Budget
You will find here the tax newsletters related to Hong Kong budget.
- HK Budget Special Report - 2011/2012
- Hong Kong Budget 2012 / 2013
- Hong Kong Budget 2013 / 2014
- Hong Kong Budget 2014 / 2015
- Hong Kong Budget 2015 / 2016
- Hong Kong Budget 2016 / 2017
- Hong Kong Budget 2017/2018
- Hong Kong Budget 2018/2019
- Hong Kong Budget 2019/2020
- Hong Kong Budget 2020/2021
- Hong Kong Budget 2021/2022
- Hong Kong Budget 2022-23
- Hong Kong Budget 2023-24
- Hong Kong Budget 2024-25
Hong Kong Tax Audit and Investigation bulletin
This quarterly bulletin aims to inform you on the latest tax audit & investigation cases.
Global Mobility Alert
Global mobility alert is a newsletter which aims to provide you with insights into changes in legislation and regulations that affect international employee mobility.
OECD BEPS - The 2015 Final Reports and the next step
On 5 October, the OECD has issued the Final Reports on the BEPS 15 Action points and it is expected that the G20 Finance Ministers will discuss and endorse the Reports and the recommended changes at their meeting on 8 October, in Lima, Peru. It is undeniable that the BEPS Action plan will dramatically reshape the existing international tax rules. The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project provides governments with solutions for closing the gaps in existing international rules that allow corporate profits to ‘disappear’ or be artificially shifted to low/no tax environments, where little or no economic activity takes place.
OECD tackles Base Erosion and Profit Shifting
The OECD ‘Action Plan on Base Erosion and Profit Shifting’ (‘BEPS’) - issued on 19 July 2013 - identifies 15 key actions along with timelines, with most actions being addressed within two years. The scale of the plan is ambitious, and will result in a dramatic change in the landscape of tax planning in the international arena. An underlying theme is tackling the artificial separation of taxable income from the activities that generate it. Going forwards, the focus will be much more on the underlying substance and where value is really created within an international business.
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