Hong Kong Taxation. Law and Practice Edition. Ayesha Macpherson Lau Garry Laird. The Chinese University Press

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1 Hong Kong Taxation Law and Practice Edition Ayesha Macpherson Lau Garry Laird The Chinese University Press

2 Acknowledgement Preface to Edition Abbreviations Latin Words and Phrases Table of Cases Board of Review Decisions IRO, IRR and SDO xvi xvii xx xxii xxiii xxxii xxxvii Chapter 1 General Scheme of Taxation in Hong Kong Law, Interpretation and Policy The Taxes in General Estate Duty (EDO) Stamp Duty (SDO) Income Taxes Year of assessment (Sec. 2) Property Tax (Part II) Salaries Tax (Part III) Profits Tax (Part IV) Depreciation allowances (Part VI) Rates of Tax (Sch. 2) Personal allowances (Sch. 4) Personal Assessment (Part VII) Returns and information (Part IX) Assessments and payment of Tax (Parts X, XA, XB, XC, and XII) Objections and appeals (Part XI) Board of Inland Revenue (Sec. 3) Inland Revenue Department Taxation System from 1 July The Basic Law The Hong Kong Reunification Ordinance 34

3 2 Property Tax Legislation Scope of the Tax The Charge Net assessable value Assessable value 40 Ownership Exemptions and Reliefs Governments Corporations and other persons carrying on business Clubs and trade associations Alternative bond schemes 50 Assessment and Payment of Property Tax 51 Time Limits and Objections 55 3 Salaries Tax 57 Legislation 59 Scope of the Tax 59 Source of the Income General Employment income Non-Hong Kong employment Hong Kong employment Holder of an office Pensions Seafarers and aircrew 80 Determination of Assessable Income Inclusions in assessable income Case law discussion Is the income from employment? Is the income for services rendered? Payments on termination of employment Payments on change of terms of employment Payments on commencement of employment Payments other than from the recipient's employer Perquisites Other issues 103

4 VI Contents Chapter 2 Property Tax Legislation 2.2 Scope of the Tax 2.3 The Charge Net assessable value Assessable value Ownership 2.5 Exemptions and Reliefs Governments Corporations and other persons carrying on business Clubs and trade associations Alternative bond schemes Assessment and Payment of Property Tax Time Limits and Objections 55 Chapter 3 Salaries Tax Legislation Scope of the Tax Source of the Income General Employment income Non-Hong Kong employment Hong Kong employment Holder of an office Pensions Seafarers and aircrew Determination of Assessable Income Inclusions in assessable income Case law discussion Is the income from employment? Is the income for services rendered? Payments on termination of employment Payments on change of terms of employment Payments on commencement of employment Payments other than from the recipient's employer Perquisites Other issues

5 VI Contents Chapter 2 Property Tax Legislation Scope of the Tax The Charge Net assessable value Assessable value Ownership Exemptions and Reliefs Governments Corporations and other persons carrying on business Clubs and trade associations Alternative bond schemes Assessment and Payment of Property Tax Time Limits and Objections 55 Chapter 3 Salaries Tax Legislation Scope of the Tax Source of the Income General Employment income Non-Hong Kong employment Hong Kong employment Holder of an office Pensions Seafarers and aircrew Determination of Assessable Income Inclusions in assessable income Case law discussion Is the income from employment? Is the income for services rendered? Payments on termination of employment Payments on change of terms of employment Payments on commencement of employment Payments other than from the recipient's employer Perquisites Other issues 103

6 vii Housing accommodation benefit Share option benefit Other perquisites Exclusions from assessable income Deductions from Assessable Income Expenses Depreciation allowances Self-education expenses Charitable contributions Home loan interest Elderly residential care expenses Retirement scheme contributions Losses Basis of Assessment Basis period and income falling therein Calculation of tax Break-even point Assessment and Payment of Tax Filing requirements Objections and appeals Provisional Salaries Tax Other Issues Treatment of payments to service companies and trusts Tax on tax Taxation of married couples The election Provisional Salaries Tax Definitions Double Taxation Agreements 189 Chapter 4 Profits Tax Legislation Scope of the Tax Liability to Profits Tax Persons chargeable Carrying on a trade, profession or business What constitutes trading Meaning of business Commencement of business Cessation of business 218

7 Source of Profits ' Statutory provisions Case law general principles Case law other issues Source of interest income IRD's practice 264 Ascertainment of Assessable Profits When income and profit arises Treatment of capital profits Other excluded profits Amounts deemed taxable Expenditure general deductibility rules When expenditure is incurred Expenditure capital v revenue Expenditure deemed deductible Deductibility of interest and related expenses Interpretation of Sec. 16(l)(a) Provisions of Sec. 16(2) Prior to 25 June Provisions of Sec. 16(2) From 25 June Expenditure deemed non-deductible Payments to "service companies" Trading stock and work-in-progress Pre-commencement expenditure Post-cessation receipts and payments Apportionment of expenses Losses Losses involving taxpayers deriving concessionary trading receipts Individuals ) 6.3 Corporations and other persons Partnerships general Limited Partnerships loss limitation Trustees 433 Basis of Assessment Normal basis Commencement Cessation Change of accounting date 443

8 ix Apportionment 447 * 4.7 Special Classes of Business Life insurance corporations Non-life insurance corporations Shipping and aircraft businesses general Shipowning businesses Resident aircraft-owning businesses Non-resident aircraft-owning businesses Financial institutions Clubs and trade associations Partnerships Alternative bond schemes Non-residents Non-residents carrying on business in Hong Kong Goods on consignment Hong Kong agents Payers other than agents Arm's length pricing Assessment and Payment of Tax 517 Chapter 5 Depreciation Allowances Legislation Scope of the Reliefs Industrial Buildings Qualifying expenditure Initial allowance Annual allowance Balancing allowances and charges Commercial Buildings (For years of assessment prior to 1998/99) Qualifying expenditure Allowances Commercial Buildings (For 1998/99 and subsequent years of assessment) Annual allowances Balancing allowances and charges Expenditure Qualifying as Plant and Machinery Plant and Machinery Allowances (General) Plant and Machinery Allowances (Pooling System) 550

9 X Contents Initial allowance Annual allowance Balancing allowance/charge Plant and Machinery Allowances (Non-Pooling System) Initial allowance Annual allowance Balancing allowance/charge Leasing When is a lease not a lease? Sale and leaseback Leveraged leases general Non-recourse debt Leveraged leases ships or aircraft Leveraged leases machinery or plant other than ships or aircraft Miscellaneous Points Relating to Depreciation Allowances Basis periods Apportionment Commissioner's powers to determine cost or value of asset 580 Chapter 6 Personal Assessment Legislation The Purpose of Personal Assessment Persons Who Qualify The Election Computation of Total Income Personal Allowances Basic allowance (Sec. 28) Married person's allowance (Sec. 29) Child allowance (Sec. 31) Dependent parent allowance (Sec. 30) Dependent grandparent allowance (Sec. 30A) Disabled dependent allowance (Sec. 31 A) Dependent brother or dependent sister allowance (Sec. 30B) Single parent allowance (Sec. 32) The Charge to Tax 608

10 xi Chapter 7 Returns and Information to Be Supplied, Penalties 7.1 Legislation 7.2 Returns and Information Returns general Persons responsible Returns by employers Information Statement of assets and liabilities Search warrants Business records Service of Notices Penalties Omissions, failure to make returns, etc Penalty assessments (additional tax) Fraud and wilful evasion Miscellaneous 643 Chapter 8 Assessments and Payment of Tax Legislation The Power to Assess General Estimated assessments Personal assessment Additional assessments Notices of Assessment 8.4 Payment of Tax 8.5 Recovery of Tax District Court procedure Collection from debtor of taxpayer Detention of defaulters leaving Hong Kong Impounding ships or aircraft Repayment of Tax 8.7 Assessments Final and Conclusive Error or omission claim (Sec. 70A) Chapter 9 Objections and Appeals Legislation 9.2 Objections The form of an objection

11 Xll Contents Negotiation of objection 673» Commissioner's determination Appeals Board of Review Appeal against decision of Board of Review Direct appeal to Court of Appeal Direct appeal to Court of First Instance Judicial Review Provisions regarding Married Couples 699 Chapter 10 Miscellaneous Matters Double Taxation Relief Exemptions Retirement Schemes Taxation consequences of retirement schemes Anti-avoidance Legislation Specific anti-avoidance Sale of loss companies General anti-avoidance provisions Sec Sec. 61A Meaning of transaction Tax benefit Sole or dominant purpose Countering the tax benefit Case law discussion Advance Rulings Sch. 10, Parti Sch. 10, Part II Other Miscellaneous Matters Board of Inland Revenue Tax Reserve Certificates Trusts, trustees and deceased estates Notice of no objection to deregister a private company 760 Chapter 11 International Aspects of Hong Kong Taxation Introduction General Principles of International Taxation 765

12 xiii Residence and source as a basis for taxation Double taxation Relief from double taxation Double taxation agreements general Structure of double taxation agreements Overview of key provisions of double taxation agreements Resolving residencerresidence conflicts Resolving source-source conflicts Permanent establishments Dividends Interest Royalties Employment income Associated enterprises Double tax relief Non-discrimination Mutual agreement procedure Exchange of information Mutual assistance in collection of taxes Other articles Anti-avoidance in an international context T ransfer pricing Controlled Foreign Corporation (CFC) rules Thin capitalisation rules Treaty shopping Tax Information Exchange Agreements International Tax Aspects of Inbound Investment Carrying on business and permanent establishments Determination of assessable profits Double tax relief Financing an investment in Hong Kong Branch vs subsidiary Transfer pricing International Tax Aspects of Outbound Investment 813

13 xiv Contents Assessability of foreign profits 813, Unilateral double tax relief Bilateral double tax relief Withholding taxes Financing a foreign investment Hong Kong expenses relating to foreign investment Transfer pricing Hong Kong Taxation Issues for Mainland Investors 823 into Hong Kong Choice of investment vehicle Comprehensive double taxation agreements Residence Carrying on a business and the existence of a permanent establishment Determination of assessable profits Other methods of computing profits Personal Taxation 830 Chapter 12 Stamp Duty Legislation Scope of the Charge The four Heads of Charge Territorial nature of charge Immovable Property in Hong Kong Conveyance on sale Gifts and transfers at less than full value Agreements for the sale of residential property Special Stamp Duty Leases Hong Kong Stock Sale and purchase Exemptions Gifts and transfers at less than full value Transfers of beneficial interest other than by way of sale Stock borrowing and lending Unit trusts Alternative bond schemes 858

14 12.5 Bearer Instruments * Duplicates and Counterparts Determination of Stamping Value What Constitutes Consideration Debts waived and assigned Methods of calculation of monetary consideration Consideration less than market value Exchange and partition of property Contingency principle Adjudication Voluntary disposition inter vivos The importance of adjudication Fee for adjudication Exemptions and Reliefs Transactions with the Government, leases of consular premises, etc Gifts in consideration of marriage Gifts to charitable institutions Transfers within a corporate group No change of beneficial interest Assessment and Payment of Stamp Duty Recovery of Stamp Duty Late Stamping Appeals Other Issues Substance over form Non-admissibility of unstamped instruments Remission of Stamp Duty by the Chief Executive Failure to disclose facts and circumstances affecting Stamp Duty Copies of instruments Electronic stamping 879 Index 881

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