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20210608 Hong Kong Tax Updates 2021
This seminar will cover the latest developments in Hong Kong tax legislation, tax cases and revenue practices in the past year. The speakers will share with the participants their insights on these developments and their implications on their businesses.
- Legislative developments:
- New tax incentives for qualifying ship leasing businesses and insurance-related businesses
- Proposed codification of the interim assessing practice as regards court-free amalgamations
- Proposed tax concessions for carried interest distributed by eligible private equity funds operating in Hong Kong
- Case law development:
- China Mobile Hong Kong Company Limited v CIR – whether upfront spectrum utilisation fee is tax deductible?
- Board of review decision D7/19 – whether royalties paid under a sale-and-license back arrangement are tax deductible under the general deduction provision and/or anti-avoidance provisions? Whether a tax treaty provision overrides the relevant provisions contained in the IRO?
- Revenue practices update:
- Change of the IRD’s practice as regards the taxation of digital businesses under DIPN 39
- Interaction of accounting standards HKFRS 15 Revenue from Contracts with Customers and HKFRS 16 Leases with the tax legislation
- Revised source rules for royalties in respect of acquired intellectual property rights