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Hong Kong Tax Newsflash

This newsletter aims to give readers a quick update on news about tax practices; development of tax cases and serves as a platform to communicate any news regarding our own tax practice to the business and professional community.

2024

Issue 230 - 12 December 2024
• Passage of stamp duty waivers for transfer of REIT units and jobbing business of options market makers

GES Tax Newsflash - 5 December 2024
• Support Assisted Reproductive Services

Issue 229 - 28 November 2024
• Enhancements to the preferential tax regimes for asset and wealth management industry under consultation

Issue 228 - 8 November 2024
• Draft legislation on stamp duty waivers for transfer of REIT units and jobbing business of options market makers gazetted

Issue 227 - 31 October 2024
• Updates on implementation of Global Minimum Tax and Hong Kong Minimum Top-up Tax

Issue 226 - 24 October 2024
• Passage of progressive rating system for domestic tenements and resumption of hotel accommodation tax

Issue 225 - 22 October 2024
• Draft legislation on enhancement measures for lease reinstatement costs and commercial/industrial building allowances gazetted

Issue 224 - 26 September 2024
• Hong Kong-Türkiye tax treaty signed

GES Tax Newsflash - 23 August 2024
• Top Talent Pass Scheme renewal

Issue 223 - 17 July 2024
• IRD's latest views on Foreign-Sourced Income Exemption (FSIE) regime

Issue 222 - 9 July 2024
• Resumption of hotel accommodation tax

Issue 221 - 8 July 2024
• Latest legislative proposal on company re-domiciliation regime

Issue 220 - 4 July 2024
• Introduction of enhancement measures for lease reinstatement costs and commercial/industrial building allowances

Issue 219 - 28 June 2024
• Hong Kong-Armenia tax treaty signed

Issue 218 - 26 June 2024
• Passage of patent box tax concession

Issue 217 - 23 May 2024
• Passage of tax measures proposed in the 2023 Policy Address and the 2024-25 Budget

Issue 216 - 30 April 2024
• Profits Tax matters discussed in the 2023 annual meeting between the Inland Revenue Department and HKICPA

Issue 215 - 16 April 2024
• Abolition of all demand-side stamp duty measures for residential properties

Issue 214 - 10 April 2024
• Draft legislation on patent box tax concession

Issue 213 - 6 March 2024
• Hong Kong-Bahrain tax treaty signed

Issue 212 - 5 March 2024
• Details of the new Capital Investment Entrant Scheme (Chinese only)

GES Tax Newsflash - 29 February 2024
• The 2024/25 Financial Budget

Issue 211 - 28 February 2024
• Hong Kong 2024/25 Budget Highlights

Issue 210 - 23 February 2024
• Passage of the enhanced aircraft leasing preferential tax regime

Issue 209 - 21 February 2024
• Hong Kong removed from EU watchlist on tax cooperation

Issue 208 - 9 February 2024
• Newly published advance ruling and updated guidance on single family office tax concession

Issue 207 - 2 February 2024
• Passage of stamp duty adjustments for residential properties

Issue 206 - 26 January 2024
• Hong Kong-Croatia tax treaty signed

Issue 205 - 19 January 2024
• Passage of tax deductions for spectrum utilization fees

2023

Year in Review 2023
• Hong Kong Tax Update Newsletter

Issue 204 - 21 December 2023
• Hong Kong Pillar 2 QDMTT / HKMTT and GloBE Rules consultation

Issue 203 - 7 December 2023
• Passage of tax certainty enhancement scheme for onshore capital gains

Issue 202 - 5 December 2023
• Inland Revenue Department issued guidance (DIPN) on court-free amalgamation and transfer of assets without sale

Issue 201 - 1 December 2023
• Draft legislation on tax deductions for spectrum utilization fees gazetted

Issue 200 - 30 November 2023
• Passage of refined Foreign-Sourced Income Exemption (FSIE) regime for disposal gains

US Tax Newsflash - 28 November 2023
• US tax authority focuses on foreign-parented groups

Issue 199 - 23 November 2023
• Enhancements of the aircraft leasing preferential tax regime

Issue 198 - 17 November 2023
• Stamp duty rate reduction on stock transfer comes into operation today

GES Tax Newsflash - 16 November 2023
• Payment made for standing by for work on rest days, statutory and public holidays is chargeable to Hong Kong Salaries Tax

GES Tax Newsflash -  30 October 2023
• The Chief Executive’s 2023 Policy Address

Issue 197 -  27 October 2023
• 2023 Policy Address – Tax-related measures

Issue 196 -  25 October 2023
• Draft legislation on tax certainty enhancement scheme for onshore capital gains

Issue 195 -  17 October 2023
• Foreign-Sourced Income Exemption (FSIE) regime for disposal gains refined – draft legislation released

Issue 194 - 7 September 2023
• Consultation on patent box tax incentive

Issue 193 - 1 September 2023
• Hong Kong-Bangladesh tax treaty signed

Issue 192 - 17 August 2023
• Updates on refinements to Foreign-Sourced Income Exemption (FSIE) regime for disposal gains

Issue 191 - 10 August 2023
• Updates on tax certainty enhancement scheme for onshore capital gains

Issue 190 - 7 July 2023
• Passage of Risk-based Capital (RBC) regime for insurance industry

Issue 189 - 3 July 2023
• New procedures on application for tax exemption status as charitable bodies

Issue 188 - 28 June 2023
• Hong Kong-Mauritius tax treaty in force

Issue 187 - 27 June 2023
• Passage of tax measures proposed in the 2022 Policy Address and the 2023-24 Budget speech

Issue 186 - 26 June 2023
• Views exchanged in the 2022 annual meeting between the Inland Revenue Department and HKICPA

Issue 185 - 12 June 2023
• Revised application forms for Certificate of Resident Status (CoR)

Issue 184 - 23 May 2023
• Company re-domiciliation regime under consultation

Issue 183 - 22 May 2023
• Adjustment of stamp duty rates on property transactions

Issue 182 - 15 May 2023
• Multilateral Instrument – Synthesised texts of tax treaties published

Issue 181 - 11 May 2023
• Proposed tax treatment regarding implementation of Risk-based Capital (RBC) regime for insurance industry

Issue 180 - 10 May 2023
• Passage of bill for family office tax concession

Issue 179 - 26 April 2023
• Proposed enhancements to family office tax concessions

Issue 178 - 25 April 2023
• Tax measures in 2023-24 Budget

Issue 177 - 19 April 2023
• Consultation on refinements to Foreign-sourced Income Exemption (FSIE) regime for disposal gains launched

Issue 176 - 27 March 2023
• Tax certainty enhancement scheme for onshore capital gain under consultation

Issue 175 - 22 February 2023
• Hong Kong 2023/24 Budget Highlights

Issue 174 - 16 February 2023
• Hong Kong still on EU watchlist, FSIE regime needs refinement

Issue 173 - 13 February 2023
• Introduction of "exit endorsement for talents" by Mainland authorities

Issue 172 -  8 February 2023
• Immigration Department appeals to residents to make appointments before applying for identity cards

Issue 171 -  3 February 2023
• OECD released administrative guidance on global minimum tax

Issue 170 - 19 January 2023
• Passage of stamp duty exemption for certain dual-counter stock transactions

2022

Year in Review 2022
• Hong Kong Tax Update Newsletter

Issue 169 - 29 December 2022
• Top Talent Pass Scheme

Issue 168 - 14 December 2022
• Passage of foreign-sourced income exemption (FSIE) regime

Issue 167 - 13 December 2022
• Extend facilitation measure to accept applications for extension of stay

Issue 166 - 9 December 2022
• Draft legislation on tax concession for family office gazetted

Issue 165 - 6 December 2022
• Updates and clarifications on foreign-sourced income exemption (FSIE) regime

Issue 164 - 14 November 2022
• Hong Kong-Mauritius tax treaty signed

Issue 163 - 11 November 2022
• Proposed amendments to the draft legislation for foreign-sourced income exemption (FSIE) regime

Issue 162 - 20 October 2022
• New Initiatives to Attract Business and Talents - Chief Executive’s 2022 Policy Address

Issue 161 - 3 October 2022
• Multilateral Instrument for tax treaty to be effective in Hong Kong

Issue 160 - 23 September 2022
• Ruling mechanism to obtain early comfort on economic activity levels for foreign-source passive income exemption

Issue 159 - 8 September 2022
• Tax concession for carried interest – guidelines on auditor's report for fund certification

18 August 2022
• Hong Kong defers the implementation of Pillar Two 

Issue 158 - 22 July 2022
• Passage of tax concessions for shipping-related activities

Issue 157 - 28 June 2022
• Passage of tax deductions for domestic rents – effective from year of assessment 2022/23

Issue 156 - 24 June 2022
• Continuation of relief measure: Waiver of surcharges for payment of tax by instalments

Issue 155 - 22 June 2022
• Foreign source income exemption regime for passive income under consultation

Issue 154 - 8 June 2022
• Proposed tax concessions for shipping-related activities

Issue 153 - 27 May 2022
• Multilateral Instrument - instrument of approval deposited for Hong Kong

Issue 152 - 17 May 2022
• Views exchanged during the 2021 annual meeting between the Inland Revenue Department and HKICPA

Issue 151 - 11 April 2022
• Passage of tax reduction measure proposed in the 2022-23 Budget

Issue 150 - 18 March 2022
• Proposed tax concession for family offices in Hong Kong

Issue 149 - 3 March 2022
• Tax measures proposed in the 2022-23 Budget speech

Issue 148 - 23 February 2022
• Hong Kong SAR Budget 2022/2023

2021

Year in Review 2021
• Hong Kong Tax Update Newsletter

Issue 147 - 30 November 2021
• Prepare for electronic filing of profits tax returns

Issue 146 - 11 November 2021
• The Legislative Assembly of the Macao Special Administrative Region held a first reading and voted on a bill to approve Tax Code (Chinese only)

Issue 145 - 6 October 2021
• Hong Kong in EU watchlist on tax cooperation due to territorial source regime

Issue 144 - 3 August 2021
• Inland Revenue Department issued guidance on tax issues arising from the COVID-19 pandemic

Issue 143 - 6 July 2021
• Hong Kong-Georgia tax treaty in force

Issue 142 - 23 June 2021
• Relief measure: waiver of surcharges for payment of tax by instalments

Issue 141 - 4 June 2021
• Passage of bills on tax treatment on amalgamation; deductions of foreign tax; filing of returns; and increased stamp duty rate on stock transfers

Issue 140 - 26 May 2021
• Apportionment method for calculating exempted income for salaries tax
purpose

Issue 139 - 29 April 2021
• Passage of tax concession for carried interest and various tax measures

Issue 138 - 19 March 2021
• New Bill on deduction of foreign tax,  court-free amalgamation and electronic filing of tax return

Issue 137 - 10 March 2021
• Gazettal of tax measures proposed in the 2021-22 Budget speech

Issue 136 - 24  February 2021
• Hong Kong SAR Budget 2021/2022

Issue 135 - 9  February 2021
• Draft legislation proposing Hong Kong tax exemption on carried interest gazetted

Issue 134 - 21 January 2021
• Tax concession for insurance-related businesses will come into operation in March 2021

Issue 133 - 6 January 2021
• Hong Kong-Serbia tax treaty in force

2020

Year in Review 2020
• Hong Kong Tax Update Newsletter

Issue 132 - 26 November 2020
• Abolishing doubled ad valorem stamp duty on non-residential property transactions

Issue 131 - 9 October 2020
• Hong Kong-Georgia tax treaty signed

Issue 130 - 7 October 2020
• Views exchanged during the 2020 annual meeting between the Inland Revenue Department and HKICPA

Issue 129 - 18 September 2020
• Inland Revenue Department requesting information on Transfer Pricing Documentation (Form IR1475)

Issue 128 - 2 September 2020
• Hong Kong-Serbia tax treaty signed

Issue 127 - 31 August 2020
• Extension of relief measure on payment of tax by instalments

Issue 126 - 27 August 2020
• Hong Kong-Macao tax treaty in force

Issue 125 - 24 August 2020
• Long awaited proposal and consultation – Hong Kong tax concession for carried interest

Issue 124 - 2 July 2020
• Inland Revenue Department issued guidance on Unified Tax Exemption Regime for funds

Issue 123 - 19 June 2020
• Passage of Concessionary Measures for Ship Leasing Businesses

Issue 122 - 11 June 2020
• Passage of Tax Reduction Measure

Issue 121 - 29 May 2020
• Tax exemption for subsidies under the Anti-epidemic Fund

Issue 120 - 15 April 2020
• Macau - Relief measures for COVID-19 epidemic

Issue 119 - 9 April 2020
• Hong Kong - Relief measures for COVID-19 epidemic

Issue 118 - 31 March 2020
• Massive US Tax Relief Act to Combat Economic Fallout From COVID-19

Issue 117 - 5 March 2020
• Arrangement between the Mainland and Hong Kong for automatic exchange of country-by-country reports in effect

Issue 116 - 28 February 2020
• Equal treatment for spouses in same-sex marriages

Issue 115 - 26 February 2020
• Hong Kong 2020/21 Budget Highlights

Issue 114 - 24 February 2020
• Introduction of concessionary measures for Ship Leasing businesses

Issue 113 - 20 January 2020
• Amendment to Macao Complementary Tax Regulations

Issue 112 - 3 January 2020
• Hong Kong-Estonia & Hong Kong-Cambodia tax treaties in force

2019

Year in Review 2019
• Hong Kong Tax Update Newsletter 

Issue 111 - 23 December 2019
• Introduction of concessionary measures for Hong Kong
Insurers – What has changed?

Issue 110 - 20 December 2019
• Extended Deadline for Local Filing of Country-by-Country ("CbC") Report in Hong Kong

Issue 109 - 13 December 2019
• Hong Kong-Mainland Double Taxation Arrangement 5th protocol in force

Issue 108 -  6 December 2019
• Hong Kong-Macao tax treaty signed

Issue 107 -  5 December 2019
• HKSAR announced new package of relief measures to support enterprises and individuals

Issue 106 -  28 November 2019
• Court of Final Appeal affirms termination payment not subject to salaries tax

Issue 105 -  20 November 2019
• Update on the Macao-Hong Kong double taxation arrangement  

Issue 104 -  7 November 2019
• Passage of Tax Reduction Measure

Issue 103 -  4 November 2019
• Hong Kong's upcoming Country-by-Country ("CbC") reporting obligations - Stocktaking before year-end

Issue 102 -  4 October 2019
• Hong Kong-Estonia tax treaty signed

Issue 101 -  2 October 2019
• Vacant property rates bill introduced

Issue 100 - 3 September 2019
• IRD made further changes to the published guidance on deduction of foreign taxes

Issue 99 - 19 August 2019
• HKSAR announced enhanced measures to support enterprises and individuals

Issue 98 - 31 July 2019
• IRD revises guidance on deduction of foreign taxes

Issue 97 - 24 July 2019
• IRD issues new guidance on Transfer Pricing and Documentation rules

Issue 96 - 28 June 2019
• Hong Kong-Cambodia tax treaty signed

Issue 95 - 4 July 2019
• Passage of 2019-20 Budget Measures Suspended 

Issue 94 - 17 May 2019
• IRD's announcement on application for Certificate of Resident

Issue 93 - 15 May 2019
• Impact of recent economic substance laws from a Hong Kong perspective

Issue 92 - 21 March 2019
• Hong Kong removed from EU watchlist on tax cooperation

Issue 91 - 13 March 2019
• Passage of Legislation on tax treatment of financial instrument and tax exemption for funds

Issue 90 - 27 February 2019
• Hong Kong 2019/20 Budget Highlights

Issue 89 - 20 February 2019
• IRD releases new version of profits tax return

Issue 88 - 18 February 2019
• The banking LAC tax ordinance in effect

Issue 87 - 25 January 2019
• Hong Kong IRD guidance on CbCR notification process

Issue 86 - 2 January 2019
• Hong Kong-Finland Tax Treaty in Force

2018

Issue 85 - 10 December 2018
• Hong Kong-India tax treaty in force

Issue 84 - 19 November 2018
• Three concessionary tax measures come into operation

Issue 83 - 15 November 2018
Bill proposes various changes: Interest paid to export credit agency, AEOI / CRS
• Interest paid to export credit agencies
• Refinement of CRS/AEOI rules
• Tax treatment of visiting teachers and researchers
• Dependent brother/sister allowance

Issue 82 - 8 November 2018
• Discussion paper on the legislative proposal on tax exemption for investment funds

Issue 81 - 7 November 2018
• Taxation of financial instruments under IFRS / HKFRS 9

Issue 80 - 5 November 2018
• Enhanced deduction regime for R&D expenditure in effect

Issue 79 - 1 November 2018
• The Banking LAC – Tax Draft Bill Explained – In Brief

Issue 78 - 29 October 2018
• Tax reserve certificate for tax in dispute

Issue 77 - 6 July 2018
• Passage of expanded deduction for purchase of intellectual property rights

Issue 76 - 13 June 2018
• Tax measures introduced to relieve individual tax burden and provide tax incentives for environmental protection and bond market

Issue 75 - 30 May 2018
• Hong Kong-Finland tax treaty signed

Issue 74 - 29 May 2018
• Passage of 2018-19 Budget measures

Issue 73 - 7 May 2018
• Amendment to offshore funds tax exemption regime in Hong Kong gazetted

Issue 72 - 28 March 2018
• Hong Kong-India tax treaty signed

Issue 71 - 22 March 2018
• Passage of two-tiered profits tax regime

Issue 70 - 28 February 2018
• Hong Kong 2018/19 Budget Highlights

Issue 69 - 26 January 2018
• Macau was removed from the European Union (EU) tax haven blacklist

Issue 68 - 22 January 2018
• Stamp duty rate for residential property increased upon passage of legislation

2017

Issue 67 - 20 December 2017
• HK-Belarus tax treaty in force

Issue 66 - 14 December 2017
• Macau is included in the EU tax haven blacklist

Issue 65 - 4 December 2017
• HK-Latvia and HK-Pakistan tax treaties in force

Issue 64 - 26 October 2017
• New tax policy directions

Issue 63 - 19 October 2017
• A step to pave the way for AEOI and BEPS actions

Issue 62 - 11 October 2017
• Tax measures announced in the Policy Address 2018/19

Issue 61 - 30 August 2017
• HK-Saudi Arabia tax treaty signed

Issue 60 - 7 August 2017
• FSDC recommends expansion of offshore PE fund profits tax exemption

Issue 59 - 1 August 2017
• Hong Kong Government releases BEPS consultation report

Issue 58 - 18 July 2017
• Open-ended Fund Company legislation progressing

Issue 57 - 13 June 2017
• Automatic exchange of financial account information (AEOI) in tax matters in Hong Kong

Issue 56 - 6 June 2017
• Passage of 2017/18 budget measures
• Update on stamp duty

Issue 55 - 24 February 2017
• HK-Pakistan tax treaty signed

Issue 54 - 22 February 2017
• 2017/18 Hong Kong Budget Highlights

Issue 53 - 23 January 2017
• HK-Belarus tax treaty signed

2016

Issue 52 - 22 December 2016
• Update on the IRD's guidelines on court-free company amalgamation

Issue 51 - 14 December 2016
• HK-Romania tax treaty in force

Issue 50 - 7 Novermber 2016
• Proposed increase of stamp duty rate for residential property transactions

Issue 49 - 14 October 2016
• IRD's annual report 2015-16

Issue 48 - 6 October 2016
• HK-Korea tax treaty in force

Issue 47 - 13 September 2016
• The Inland Revenue Department issues guidance on corporate treasury centre rules

Issue 46 - 18 August 2016
• 3rd protocol of Macau-Mainland China Tax Treaty was signed

Issue 45 - 12 August 2016
• HK-Russia tax treaty in force

Issue 44 - 24 June 2016
• Passage of new law for Automatic Exchange of Information (AEOI)

Issue 43 - 17 June 2016
• Update on Certificate of Hong Kong Resident Status (CoR) Application

Issue 42 - 6 June 2016
• The Inland Revenue Department Issues Guidance on Extended Offshore Funds Law

Issue 41 - 27 May 2016
• Passage of Hong Kong Corporate Treasury Centre rules

Issue 40 - 24 May 2016
• Passage of 2016/17 Budget Measures

Issue 39 - 9 May 2016
• BEPS in Hong Kong – How the IRD reacts?

Issue 38 - 27 April 2016
• HK-Latvia tax treaty signed

Issue 37 - 26 April 2016
International Tax Newsflash
• United Kingdom Budget 2016 announced

Issue 36 - 24 February 2016
• 2016/17 Budget Highlights

Issue 35 - 29 January 2016
• HK-Russia tax treaty signed
• AEOI bill gazetted

2015

Issue 34 - 23 December 2015
• HK-UAE tax treaty in force

Issue 33 - 27 November 2015
• HK-Romania tax treaty signed

Issue 32 - 25 November 2015
• IRD's latest view on Certificate of Sesident Status

Issue 31 - 12 November 2015
• Mainland referral letter not required for Certificate of HK Resident Status application
• HK-South Africa tax treaty in force

Issue 30 - 20 October 2015
• HK's tax co-operation status clarified
• HK Government's commitment to AEOI
• Orders on TIEAs with Nordic jurisdictions and HK-China DTA 4th protocol gazetted
• HK-Italy tax treaty in force

Issue 29 - 17 July 2015
• Breaking News: Profits Tax Exemption Law for Private Equity Funds in effect

Issue 28 - 13 July 2015
• Passage of 2015/16 Budget measures

Issue 27 - 9 July 2015
• Notes exchanged with Japan regarding the EoI article in CDTA in force

Issue 26 - 26 March 2015
International Tax Newsflash
• United Kingdom Budget 2015 announced 
(bilingual version)

Issue 25 - 24 March 2015
• Expansion of the Offshore Funds Law - Inland Revenue (Amendment) Bill 2015

Issue 24 - 27 February 2015
• HK-Vietnam DTA (2nd Protocol) entered into force

Issue 23 - 25 February 2015
• 2015/16 Budget highlights

Issue 22 - 24 February 2015
• Stamp duty waiver for ETFs

Issue 21 - 4 February 2015
• Revised application forms for tax resident certificate

2014

Issue 20 - 15 December 2014
• THK-UAE tax treaty signed
• Notes exchanged with Japan regarding the EoI article in CDTA
• Stamp duty waiver for ETFs
• Practice notes issued by the IRD
• The IRD's Annual Report 2013-14
• Tax return administration

Issue 19 - 3 November 2014
• Tax issues discussed in the annual meeting between the IRD and HKICPA

Issue 18 - 23 October 2014
• HK-South Africa Tax Treaty signed
• Orders gazetted: HK-Korea DTA / HK-Vietnam DTA (2nd Protocol)

Issue 17 - 10 July 2014
• Hong Kong-Korea Tax Treaty signed

Issue 16 - 30 June 2014
• Passage of 2014-15 Budget
• HK-US TIEA entered into force

Issue 15 - 21 February 2014
• Immigration Department steps up enforcement during Chinese New Year: Nonresident performers reminded to comply with Hong Kong immigration and tax rules

Issue 14 - 25 March 2014
• Bill passed to lower tax of captive insurers
• Company fined for failure to notify chargeability

Issue 13 - 2 January 2014
• Hong Kong - Qatar Tax Treaty in force
• Inland Revenue (Amendment) Bill gazetted

2013

Issue 12 - 2 December 2013
• Proposed profits tax exemption on private equity funds

Issue 11 - 15 November 2013
• Nice Cheer Case Update: Taxpayer won again in the Court of Final Appeal

Issue 10 - 26 July 2013
• Update on DIPN 49 re intellectual property rights
• Hong Kong-Kuwait Tax Treaty in force

Issue 8 - 14 May 2013
• Hong Kong - Qatar Tax Treaty signed

Issue 7 - 8 May 2013
• Hong Kong-Malaysia Tax Treaty effective procedures for putting Tax Treaty into effect

Issue 6 - 26 April 2013
• Hong Kong – Guernsey Tax Treaty signed

Issue 5 - 22 April 2013
• Tax Information Exchange Agreements (TIEAs) Inland Revenue (Amendment) Bill 2013 gazetted

Issue 4 - 26 February 2013
• Further measures on Ad Valorem Stamp Duty to address the overheated property market

Issue 3 - 22 January 2013
• Application of Section 15(1)(ba) in dispute

Issue 2 - 16 January 2013
• Hong Kong - Italy Tax Treaty Signed

Issue 1 - 1 January 2013
• Clarification on HK-France DTA sought: Branch Remittance Tax in France exempted

Hong Kong Tax Spotlights

Issue 2 - December 2011
[English

Issue 1 – June 2011 
[English

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