Hong Kong Tax Controversy Services
Managing tax controversy with expert insights
Who are we?
Our professional team includes former Inland Revenue Department (IRD) official, and can advise and assist clients at all phases of the tax controversy cycle. The team is specialized in advising and assisting clients in resolving field audit and tax investigations, offshore profit claims, potential tax irregularities and appeal cases handled by the IRD's Appeals Section etc.
Our team has extensive experience in handling tax controversy cases, including working experience in the IRD and is conversant with its work procedures and practices. The team specializes in liaising with IRD'assessors, focusing on addressing the IRD's major concerns in each case, and aiming at resolving the tax controversy cases by compromise settlement.
We have successfully assisted clients, including multi-national corporations, Chinese Mainland enterprises, Hong Kong private companies and high-net-worth individuals, in liaising with the IRD for compromise settlement of tax audit cases. In respect of long-outstanding queries from the IRD (including offshore income, controversial deduction claim, etc.), we focus on technical arguments and special circumstances to assist clients in their applications to the IRD.
We also assist clients in analysing the implications of tax matters in any irregularities identified (including the level of compliance, potential penalty, etc.). In addition, we advise clients on the possible remedial actions and assist in liaising with the IRD accordingly.
We are committed to assisting clients in formulating the appropriate strategies and approaches, from technical and pragmatic perspectives, for resolving tax disputes with the IRD on a compromise basis, instead of taking the case to the appeal channel.
We offer a wide range of tax consulting services to clients of all industries concerning tax controversy, including but not limited to:
Field Audit & Investigation
Conducting mock interviews with clients before formal meetings with the IRD; assisting clients in preparing for the IRD's enquiries during the Initial Interview; assisting in response to IRD queries; proposing strategies based on the approach adopted by the IRD; and proactively liaising with the IRD to seek compromise settlement of cases.
Analysis of level of compliance/penalty exposure
Analyzing the financial and tax position of clients and the level of compliance, and liaising with the IRD on potential irregularities identified.
Handling IRD enquiries
Assisting in furnishing replies to IRD queries, particularly concerning significant tax impact, proposing an overall strategy to handle the cases and the relevant supporting documents.
Past successful cases involved:
- Offshore trading profits
- Offshore interest income
- Offshore service fee income
- Gains on disposal of assets (including investment gain, disposal of land and properties)
- Controversial deduction claims (including compensation and claims and service fees to related parties)
- Royalty/license fees and withholding tax
- Profit allocation
Revision of prior years' tax return filings
Providing clients with technical support and assisting in formulating technical arguments; assisting in addressing possible IRD queries; where appropriate, assisting in liaising with the IRD to apply for a tax refund or a lower penalty (in cases involving additional tax).
In respect of tax controversy cases handled by the IRD's Appeals Section, reviewing the cases and assisting in exploring and liaising with the IRD for a compromise settlement.