Hong Kong tax newsletters
Mazars’ comments on Hong Kong tax issues.
December 2015 - Hong Kong Proposes To Provide Tax Incentives for Corporate Treasury Centres
As reported in our 2015-2016 Hong Kong Budget News issued in February 2015, in order to enhance Hong Kong’s attractiveness as a Corporate Treasury Centre to multinational corporations, the Financial Secretary announced that the Government would amend the Inland Revenue Ordinance (“IRO”) to provide tax incentives for corporate treasury centres (“CTCs”) in Hong Kong by introducing a concessionary profits tax rate for qualifying profits derived by a qualifying CTC, and allowing interest expense deductions on monies borrowed from non-Hong Kong associated corporations carrying out intra-group financing business. The relevant provisions are set out in the Inland Revenue (Amendment) (No. 4) Bill 2015 (“the Bill”) which was gazatted on 4 December 2015. (1)
The Bill has been introduced into the Legislative Council (“LegCo”) on 16 December 2015 for scrutiny and approval. Upon enactment of the Bill, the relevant tax provisions will apply from 1 April 2016.
The Bill has been introduced into the Legislative Council (“LegCo”) on 16 December 2015 for scrutiny and approval. Upon enactment of the Bill, the relevant tax provisions will apply from 1 April 2016.
October 2015 - Taxability of License Fees Under Deeming Provision
In May 2015, the Court of Appeal (“CoA”) handed down its judgment in Turner Entertainment Networks Asia, Inc. (“Turner”) for Muse Communications Co.,Ltd (“Muse”) v. the Commissioner of Inland Revenue(“CIR”) that license fees received by a non-Hong
Kong resident, Muse, for granting rights to a Hong Kong taxpayer, Turner, to exhibit television programs outside Hong Kong are chargeable to tax in Hong Kong.
Kong resident, Muse, for granting rights to a Hong Kong taxpayer, Turner, to exhibit television programs outside Hong Kong are chargeable to tax in Hong Kong.
Mar. 2014 - First TIEA signed by Hong Kong
Hong Kong (“HK”) has just signed an agreement for Exchange of Information (“EoI”) with the United States of America (“US”) on 25 March 2014.
Jan. 2014 - Mazars' budget proposal 2014-2015
Mazars submitted its 2014/2015 Hong Kong Budget Proposal to the Financial Secretary on 10 January 2014.
Feb. 2014 - Tax concession to promote Hong Kong as a potential domicile for captives
In Hong Kong, a captive insurer is defined under the Insurance Companies Ordinance as an insurer which carries on general business only and is restricted to underwriting insurance and reinsurance of risks of the companies within the same group of companies to which the captive insurer belongs.
Comprehensive Double Taxation Agreements (CDTA)
List of Comprehensive Double Taxation Agreements (CDTA) signed between Hong Kong and other countries.
May 2015 - Comprehensive Double Taxation Agreements with South Africa and United Arab Emirates
BACKGROUND
On 15 May 2015, 2 orders made by the Chief Executive were gazetted to implement the Comprehensive Agreements for the Avoidance of Double Taxation (“CDTAs”) with South Africa and the United Arab Emirates (“UAE”) that were signed in October 2014 and November 2014 respectively.
The CDTAs will enter into force after both Hong Kong and the treaty partners have completed their ratification procedures.
On 15 May 2015, 2 orders made by the Chief Executive were gazetted to implement the Comprehensive Agreements for the Avoidance of Double Taxation (“CDTAs”) with South Africa and the United Arab Emirates (“UAE”) that were signed in October 2014 and November 2014 respectively.
The CDTAs will enter into force after both Hong Kong and the treaty partners have completed their ratification procedures.
April 2015 - Hong Kong proposes to extend offshore funds tax exemption to private equity
Hong Kong is a major international financial centre (“IFC”). Financial service industry is one of the four pillar industries which have been a driving force of Hong Kong’s economic growth for years. Fund and asset management business is an important component and a fast- growing area in financial service industry.
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