• Tax Corner

Advance Ruling in Hong Kong

In general, application of advance ruling is only eligible when it regards certainty in respect of determination on the source of income, whether or not a taxpayer is carrying on business in Hong Kong. The application to the Commissioner of Hong Kong Inland Revenue Department (HKIRD) must be submitted before the submission deadline of the relevant tax return (e.g. Profits Tax Return for Corporation).

Disclosure Requirements

  • Question(s) must be clearly stated to the Commissioner for review and answer
  • Issue(s) must be identified in which the taxpayer needs to resolve
  • A full description of the facts and the arrangement in question to be provided
  • Provision(s) of the IRO must be stated in respect of which the ruling is sought
  • Propositions of law with law cases must be stated which are relevant to the issues raised in the application. Also any legal reasons and arguments should be mentioned to support the application to the Commissioner
  • The applicant must provide a draft ruling

Note: The Commissioner has the right at any time request further relevant information when reviewing the application.

Holiday Notice: The first day of January 2019
Please note that Atrix will be closed on 1 January (Tuesday), and our service to be resumed on 2 January (Wednesday).

Waiving business registration fees for 2019/20
In Hong Kong 2019-20 Budget, the Financial Secretary proposed a waiver of 2019/20 business registration fees of HKD 2,000.   Read more

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The Financial Secretary of the HKSAR Government will provide new resources ready for use of about HKD 150 billion in the 2019-20 Hong Kong Budget, with additional resources earmarked for various purposes.   Read more