The Asia-Pacific Journal of Taxation (APJT) is a joint effort between the Taxation Institute of Hong Kong and the School of Accounting and Finance of The Hong Kong Polytechnic University.

It publishes research papers, commentary notes, book reviews and articles that address significant issues in the field of taxation relevant to Hong Kong, China and the Asian Pacific region.

The APJT aims to provide quality service to the readership by making its content ore informative and thorough, and by striking a proper balance between professionalism and intellectual stimulation.

The APJT normally publishes two issues every year.

Feature Articles
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It has been the objective of the Taxation Institute of Hong Kong (TIHK) to enhance the standard of the tax profession and to promote the study of taxation. The Asia-Pacific Journal of Taxation (APJT) was created in 1997 as part of the measures to fulfil these objectives. Most of the members of the TIHK are tax practitioners. During the past years, the APJT has published many valuable in-depth articles from academics and practising professionals on different issues covering mainly Hong Kong tax and China tax and has enabled TIHK members to update themselves technically on the latest issues in Hong Kong and China taxation. These articles have provided practitioners with valuable insights when they are serving their clients.

 

From past surveys, it is clear that members of the TIHK find the APJT very useful and informative. The APJT, and especially its Board of Review (BOR) column which provides information on the current views of the Inland Revenue Department (IRD) and the BOR, is one of the reasons why practitioners join the TIHK.

 

With the changing global tax environment created by the Base Erosion Profit Shifting (BEPS) initiative of the OECD, the Belt and Road initiative, and the development of the Greater Bay Area, both the IRD and tax practitioners are facing many challenges.

 

Hong Kong has been subject to Global Forum peer review since 2011. The Global Forum on Transparency and Exchange of Information for Tax Purposes is a multilateral framework for tax transparency and information sharing within which 150 jurisdictions participate on an equal footing. The Global Forum monitors and peer reviews the implementation of international standards on exchange of information on request (EOIR) and automatic exchange of information (AEOI). Hong Kong has passed both phase 1 and phase 2 of the review on EOIR. As Hong Kong has implemented AEOI legislation, the Global Forum will initiate the peer review on AEOI soon. The BEPS initiative, which includes 15 actions, was introduced in 2015 after years of consultation and promotion by the OECD. Hong Kong has adopted the minimum standard of actions 5 (harmful tax practice), 6 (treaty abuse), 13 (transfer pricing documentation), 14 (dispute resolution), and 15 (multilateral instrument), and we understand that the IRD has increased its manpower to handle these policy issues on BEPS and other objectives.

 

The Hong Kong Government has introduced a number of amendments to the Inland Revenue Ordinance. The IRD has amended the part of the ordinance concerning a corporate treasury centre and captive insurance in compliance with BEPS Action 5. In July 2018, the Legislative Council passed the Inland Revenue (Amendment) (No. 6) Bill 2017 which is related to transfer pricing and dispute resolution, and the IRD is now drafting its departmental note on this. On 24 October 2018, the Legislative Council passed the Inland Revenue (Amendment) (No. 3) Bill 2018 on the super-deduction of R&D. In November 2018, the government gazetted the Inland Revenue (Amendment) (No. 7) Bill 2018 which seeks to align the tax treatment of financial instruments, refine the provisions that implement the arrangement for automatic exchange of financial account information (AEOI), and avoid the potential double non-taxation of the income of visiting teachers and researchers. We are sure that the IRD will draft its departmental note once the bill has been passed. We understand there are many more amendments in the pipeline.  

 

Given the above-mentioned changes, tax practitioners in Hong Kong face many challenges and competitions. Nowadays, not only are multinational taxpayers knowledgeable in taxation, but so too are many SME taxpayers. They can obtain taxation information from various media. As such, practitioners must keep abreast of current developments in taxation and their implications not just in Hong Kong but globally.

 

In view of all these changes in the taxation environment and the knowledge requirement for practitioners, the APJT is undergoing changes in order to assist members to face the challenges of these new developments.

 

The APJT is the only taxation journal jointly publish by the TIHK and Hong Kong Polytechnic University (PolyU) in Hong Kong. In the past five years, we have featured more articles on international taxation, especially on BEPS, in addition to the column on Hong Kong and PRC taxation. We have also established a column on the Belt and Road countries to give readers a basic knowledge of the tax systems of these countries. In 2011, the APJT signed a memorandum of understanding with the Asia Oceania Tax Consultants’ Association (AOTCA), a tax practitioner association in the region of which the TIHK is a member, to share our articles with them.

 

As mentioned, the APJT is primarily a technical publication for members of the TIHK. In the last issue, we introduced a Letters to the Editors column to give members the opportunity to express their views on the practical day-to-day issues they encounter (e.g. their experiences with the IRD) and on any upcoming IRD policy.

 

In the spirit of environmental protection and global digitalisation, we have decided to publish an e-version of the APJT in the near future. Members can opt to receive the Journal in e-version or hard copy. Furthermore, in order to serve members more, we have decided to create a digital database for the APJT. Members will be able to use keyword search to locate past articles: for example, if a member wants to read all the articles on “territorial tax base” published in the APJT, the database will be able to provide such information. Certainly, we will need some time to input all the articles into the database.

 

In the coming months, the TIHK will conduct a member survey. We sincerely urge members to give us their views on the APJT: Do you still find it useful? What are your views on the changes we have introduced or are going to introduce?

 

We would like to express our heartfelt gratitude to the authors for contributing insightful articles; to the contributors to the Letters to the Editors column for their views and suggestions; to the reviewers for their valuable comments; to the staff of the TIHK for co-ordinating with the authors, reviewers, and publisher; and, last but not least, to our readers for the continuous support they have given to the APJT. Finally, we would like express our deepest gratitude to our founding editors from PolyU: Without their devoted time and guidance, the APJT would not have been so successful.

 

The Joint Editors

December 2018