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Multilateral Instrument: The Application of Specific Activity Exemption Article to Covered Tax Agreements

17 Jan 2020

Action 7 - 2015 Final Report under the OECD/G20 BEPS Action Plan, titled “Preventing the Artificial Avoidance of Permanent Establishment Status”, addresses the issue of artificial avoidance of permane...Read More


Multilateral Instrument: Examining Artificial Avoidance of PE Status Articles under Action 7 of BEPS Project

3 Oct 2019

The definition of permanent establishment (PE) included in tax treaties is crucial in determining whether a non-resident enterprise must pay income tax in another State. The PE concept is central to t...Read More


Multilateral Instrument: Analysis on the Application of the Entry-into-Force and the Entry-into-Effect Articles to Covered Tax Agreements

2 Sept 2019

The MLI has been designed to strengthen existing tax treaties concluded among its parties without the need for burdensome and time-consuming bilateral renegotiations. The analysis will cover Article 3...Read More


Analysis on the Application of Articles 7(6) and 7(7) of the Multilateral Instrument to the Covered Tax Agreements

24 July 2019

Article 7 – Prevention of Treaty Abuse – of the Multilateral Instrument (the MLI) contains three opt-in provisions. Two of them, Article 7(6) and 7(7), relate to the adoption of the simplified limitat...Read More


Application of Article 6 (Purpose of a Covered Tax Agreement) of the Multilateral Instrument to Covered Tax Agreements

20 May 2019

Articles 3 to 17 under Part II to V of the Multilateral Instrument provisions are substantive provisions addressing the BEPS issues. The substantive provisions have the common structure including oper...Read More


Introduction of the Entry-into-Effect Date Article of the Multilateral Instrument under the BEPS Action 15

9 May 2019

Article 35(1) provides that the Multilateral Convention shall take effect in each contracting jurisdiction with respect to the covered tax agreement. For taxes withheld at source on amounts paid or cr...Read More


How Mutual Agreement Procedure under the Multilateral Instrument Applies to Covered Tax Agreements

5 March 2019

A Mutual Agreement Procedure (MAP) is the dispute resolution mechanism contained in the article of double tax treaties concluded between the tax authorities (the competent authorities). This article a...Read More


Individual Income Tax Law amendment on Sept 1, 2018 and effective on 1st January 2019

18 Jan 2019

China's Individual Income Tax Law (IIT) was amended on 1 September 2018 and effective on 1 January 2019. The 2018 amendment of the PRC IIT law has impact on after-tax income, the definition of PRC tax...Read More


Analysis on the Capital Gains Article under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS

4 Dec 2018

This article examines the structure of the multilateral instrument (the MLI), the interaction between the operative clauses and the compatibility clauses, and the application of different types of opt...Read More


The Application of the Articles in the Multilateral Convention to HK’s Tax Treaties

13 Sept 2018

The purpose for a contracting jurisdiction (i.e. Hong Kong) to make notification to the OECD Depositary is twofold: to ensure clarity and transparency about the application of the MLI; and acquire the...Read More


Comparison Between the Old and the Amended PRC VAT Rules

19 March 2018

On 1st Dec 2017, the State Council issued a decree signed by Premier Li Keqiang, publicizing the content of a circular amending the previous interim VAT regulations and abolishing the business tax, ef...Read More


Reporting by Trust companies and Trust under the HK CRS Rules

3 Oct 2017

Hong Kong’s Common reporting rules became effective June 30, 2016. This article compares Hong Kong’s common reporting standard with other versions and raises some questions that the authorities should...Read More


Comments on HK’s AEOI legal framework

27 July 2017

A jurisdiction that commits itself to the Standard for Automatic Exchange of Financial Information in Tax Matters (the CRS) may sign the Multilateral Convention on Mutual Administrative Assistance in ...Read More


The Highlight of Significant Controllers in the Companies Amendment Bill 2017

11 July 2017

The Highlight of Significant Controllers in the Companies Amendment Bill 2017...Read More


An Update on Hong Kong’s Commitment to Automatic Exchange of Information in Tax Matters

11 Oct 2016

The Inland Revenue (Amendment) (No. 3) Ordinance became effective on 30th June 2016, with the objective to the implementation of Automatic Exchange of Information ('AEOI') that is in compliance with t...Read More


Why the RMB is depreciating?

7 Jan 2016

Only three trading days into the year of 2016, the dollar in the offshore market has already appreciated against the yuan by 2.35%, exceeding the interest earned from 2-year RMB time deposit...Read More


Administrative Measure for Managing the Treaty Treatments Claimed by Non-resident Taxpayers under Tax Treaties

7 Dec 2015

With a view to implementation of the double tax agreements (including the double tax arrangement concluded with the governments of the Hong Kong SAR and Macau SAR, called “the double tax treaties” her...Read More


Tax Opinion on Gain Arising From Indirect Transfer of PRC Landed Property

25 Nov 2015

In respect of the intended disposal of shares in the HK Company owning the properties located in Shanghai, we take pleasure in providing your client (a Hong Kong company) with the tax opinion, as set ...Read More


What is a DTA and how does it work?

24 Feb 2015

DTA is short for double tax agreement. It is also called double tax treaty (DTT). Countries or states sign DTA’s in order to achieve the following major objectives: avoidance of double taxation, alloc...Read More


The Financial Year and Its Related Legal Concept under the Companies Ordinance

9 Jan 2015

The Company’s financial year, as defined under section 367 of the Companies Ordinance (Cap 622), is the key to understand Part 9 (Accounts and Audits) of the Companies Ordinance (the CO), which includ...Read More

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