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Latest Tax Analysis

New cross-border e-commerce policies announced

P289/2018 – 28 December 2018

The Chinese government recently announced several administrative and tax policies relating to cross-border e-commerce (CBEC) retail imports, i.e. direct internet (or other online network) purchases of goods by Chinese individual consumers from overseas retailers via Chinese e-commerce services providers.

(English version)

Year 2018

P289/2018 - 28 December 2018
New cross-border e-commerce policies announced

[English] [Simplified Chinese]

P287/2018 – 24 December 2018
Individual Income Tax Reform: Final implementation regulations for IIT law released
[English] [Simplified Chinese

P286/2018 – 24 December 2018
Individual Income Tax Reform: Guidance released on additional itemized deductions
[English] [Simplified Chinese] [Japanese]

P285/2018 – 21 December 2018
Individual Income Tax Reform: Guidance released on tax withholding under new IIT law
[English]

P282/2018 – 22 October 2018
Individual Income Tax Reform: Draft implementation regulations released for public consultation
[English] [Simplified Chinese] [Japanese]

P281/2018 – 22 October 2018
Individual Income Tax Reform: Consultation Paper released on additional itemized deductions
[English] [Simplified Chinese] [Japanese]

H86/2018 – 3 October 2018
Overview of tax law changes under new BEPS law
[English

P278/2018 – 17 September 2018
Aligning China R&D arrangements and transfer pricing in a post BEPS world
[English] [Simplified Chinese] [Japanese]

P277/2018 – 3 September 2018
Individual Income Tax (IIT) Reform: Amended IIT Law approved
[English] [Simplified Chinese] [Japanese]

H85/2018 – 22 January 2018
IFRS 17: Tax issues in Asia Pacific
[English]

P276/2018 – 3 August 2018
WCO releases 2018 "Guide to Customs Valuation and Transfer Pricing"
[English] [Simplified Chinese] [Japanese]

H84/2018 – 27 July 2018
Court of Appeal rules "Initial Payment" arising from redevelopment arrangement taxable
[English

H83/2018 – 13 July 2018
Hong Kong passes BEPS and Transfer Pricing laws
[English] [Simplified Chinese] [Japanese]

P275/2018 – 3 July 2018
Individual Income Tax Reform: Draft amendments released for public consultation 
[English] [Simplified Chinese] [Japanese]

H82/2018 – 4 May 2018
Enhanced deduction for R&D expenditures introduced
[English] [Simplified Chinese]

H81/2018 – 18 April 2018
Proposed expansion of deduction for purchase of intellectual property rights
[English] [Simplified Chinese]

P274/2018 – 6 April 2018
Guidance issued on new VAT rate reductions and changes relating to small-scale VAT payers
[English] [Simplified Chinese] [Japanese]

P273/2018 – 8 March 2018
Customs credit management system revised
[English] [Simplified Chinese] [Japanese]

H80/2018 – 28 February 2018
2018/19 Budget analysis
A holistic budget with forward-looking vision
[English] [Simplified Chinese]

H79/2018 – 27 February 2018
Employer-employee relationship
[English] [Simplified Chinese]

P271/2018 – 23 February 2018
SAT updates guidance on interpretation of tax treaties
[English] [Simplified Chinese] [Japanese]

P270/2018 – 8 February 2018
SAT published new rules on beneficial owners
[English] [Simplified Chinese] [Japanese]

H78/2018 – 6 February 2018
Permanent Establishments
[English]

P269/2018 – 17 January 2018
SAT issues guidance on registration of general VAT payers
[English] [Simplified Chinese] [Japanese]

P268/2018 – 10 January 2018
Tariff adjustments for 2018 announced
[English] [Simplified Chinese] [Japanese]

H77/2018 – 8 January 2018
Hong Kong to introduce statutory transfer pricing regime
[English] [Simplified Chinese] [Japanese]

H76/2018 – 5 January 2018
Two-tiered profits tax rates regime introduced in Hong Kong
[English] [Simplified Chinese]

Year 2017

P265/2017 – 27 October 2017
New guidance clarifies rules relating to EIT withholding on China-source income derived by nonresident enterprises
[English] [Simplified Chinese] [Japanese]

H75/2017 – 1 August 2017
Hong Kong signs multilateral instrument to modify bilateral tax agreements
[English] [Simplified Chinese]

P264/2017 – 1 August 2017
China signs MLI to modify tax treaties
[English] [Simplified Chinese] [Japanese]

P263/2017 – 28 July 2017
New VAT guidance issued on industry-specific issues
[English] [Simplified Chinese] [Japanese]

P262/2017 – 3 July 2017
VAT on asset management products postponed
[English] [Simplified Chinese] [Japanese]

P261/2017 – 28 June 2017
SAT strengthens management of VAT general invoices
[English] [Simplified Chinese] [Japanese]

P260/2017 – 1 June 2017
Consequences of reduction in VAT rate bands
[English] [Simplified Chinese] [Japanese]

P259/2017 – 22 May 2017
China CRS rules apply as from 1 July 2017    
[English] [Simplified Chinese] [Japanese]

P258/2017 – 31 March 2017
SAT issued new rules to improve administration of special tax investigation and adjustment and mutual agreement procedures 
[English] [Simplified Chinese] [Japanese]

H74/2017 – 28 March 2017
Oops!…They did it again
Hong Kong's aircraft leasing bill
[English] [Simplified Chinese]

H73/2017 – 22 February 2017
2017/18 Budget Analysis
Comprehensive, but cautious budget with commitment to review long-term tax policy
[English] [Simplified Chinese]

P256/2017 – 26 January 2017
Government authorities coordinate to offer joint incentives for customs advance certified enterprises
[English] [Simplified Chinese] [Japanese]

H72/2016 – 16 January 2017
Financial Institutions: Practice versus Law and Foreign Tax Credits?
[English] [Simplified Chinese]

P255/2016 – 10 January 2017
SAT clarifies post-VAT reform land appreciation tax issues
[English] [Simplified Chinese] [Japanese]

Year 2016

P254/2016 – 27 December 2016
New VAT guidance addresses industry-specific issues
[English] [Simplified Chinese] [Japanese]

H71/2016 – 16 December 2016
Hong Kong Consultation on measures against BEPS
[English] [Simplified Chinese] [Japanese]

P253/2016 – 13 December 2016
GAC issues 2017 edition of Harmonized System Nomenclature
[English] [Simplified Chinese] [Japanese]

P252/2016 – 22 November 2016
Update on export tax refunds: Revised guidance on administrative classification of export enterprises
[English] [Simplified Chinese] [Japanese]

P251/2016 – 7 November 2016
Chinese customs authorities issue updated guidance on customs audits
[English] [Simplified Chinese] [Japanese]

P250/2016 – 28 October 2016
Comprehensive resource tax reform kicked off in China - Water resource tax piloted in Hebei province
[English] [Simplified Chinese] [Japanese]

P248/2016 – 18 October 2016
SAT issued new rules to improve administration of advance pricing arrangements
[English] [Simplified Chinese] [Japanese]

P247/2016 – 17 October 2016
State Administration of Taxation ("SAT") released draft "Due Diligence Procedures on Financial Account Information in Tax Matters for Non-residents" Are you ready?
[English] [Simplified Chinese]

P245/2016 – 28 September 2016
Favorable tax treatment extended to more equity compensation plans / contributions of technology
[English] [Simplified Chinese]

P244/2016 – 8 September 2016
VAT Reform - SAT clarifies disputed VAT issues
[English] [Simplified Chinese] [Japanese]

P243/2016 – 8 August 2016
Chinese court rules offshore merger by absorption does not qualify for special reorganization relief
[English] [Simplified Chinese] [Japanese]

P242/2016 – 4 August 2016
New China - Germany agreement on the avoidance of double taxation and the prevention of fiscal evasion
[English] [Simplified Chinese]

P241/2016 – 13 July 2016
SAT issued new rules on reporting of related party transactions and contemporaneous documentation
[English] [Simplified Chinese] [Japanese]

P240/2016 – 27 May 2016
VAT Reform – SAT promulgated interim measures related to real estate and construction sectors
[English] [Simplified Chinese] [Japanese]

P238/2016 – 6 April 2016
VAT Reform – SAT promulgated interim measures related to real estate and construction sectors
[English] [Simplified Chinese] [Japanese]

H70/2016 – 6 April 2016
Impact of BEPS Action 6 on source-based tax jurisdictions: the case of Hong Kong
[English] [Simplified Chinese]

P236/2016 – 2 April 2016
VAT Reform - Construction sector
[English] [Simplified Chinese] [Japanese]

P235/2016 – 30 March 2016
VAT Reform - Lifestyle services sector
[English] [Simplified Chinese] [Japanese]

P234/2016 – 29 March 2016
VAT Reform - Financial services sector
[English] [Simplified Chinese] [Japanese]

P233/2016 – 31 March 2016
VAT Reform - Real estate sector  
[English] [Simplified Chinese] [Japanese]

P232/2016 – 24 March 2016
MOF and SAT announced detailed rules for VAT Reform rollout to cover all industries 
[English] [Simplified Chinese] [Japanese]

H69/2016 – 16 March 2016
Potential impact of proposed Regulatory Capital Securities tax legislation to Hong Kong financial institutions
[English] [Simplified Chinese]

H68/2016 – 24 February 2016
2016/17 Budget Analysis - Commitment to long-term growth, but lack of exciting relief measures
[English] [Simplified Chinese]

H67/2016 – 20 January 2016
IRD partially clarifies tax treatment of court-free amalgamations
[English] [Simplified Chinese]

Year 2015

H66/2015 – 11 December 2015
Hong Kong aims to sharpen its competitive edge with new corporate treasury centre tax regime
[English] [Simplified Chinese]

H65/2015 – 18 November 2015
Hong Kong profits tax exemption for private equity funds: Now a reality
[English] [Simplified Chinese]

P231/2015 – 16 November 2015
Results of high and new technology enterprise status verification announced
[English] [Simplified Chinese] [Japanese]

P230/2015 – 15 October 2015
BEPS action 7: Preventing the artificial avoidance of PE status
[English] [Simplified Chinese] [Japanese]

P229/2015 – 7 October 2015
Final BEPS reports released: An overall perspective
[English] [Simplified Chinese] [Japanese]

P228/2015 – 22 September 2015
Mainland China and Taiwan sign tax agreement
[English] [Simplified Chinese] [Japanese]

P227/2015 – 21 September 2015
SAT issues new rules for claiming treaty benefits
[English] [Simplified Chinese] [Japanese]

P226/2015 – 21 September 2015
Discussion draft of "Implementation Measures of Special Tax Adjustment" released by the China's State Administration of Taxation
[English] [Simplified Chinese] [Japanese]

P225/2015 – 13 August 2015
China issues regulations on cost sharing agreements
[English] [Simplified Chinese] [Japanese]

P224/2015 – 6 August 2015
Free trade agreement signed with Australia
[English] [Simplified Chinese]

P223/2015 – 27 July 2015
BEPS Actions 8, 9 and 10: Transfer pricing update
[English] [Simplified Chinese] [Japanese]

H64/2015 – 22 July 2015
A Hong Kong perspective on the EU efforts to prevent harmful tax competition
[English] [Simplified Chinese]

P222/2015 – 17 July 2015
SAT issues guidance on tax administration of enterprise reorganizations
[English] [Simplified Chinese] [Japanese]

P221/2015 – 15 July 2015
SAT issues new guidance on special tax treatment on intragroup assignment of shares or assets
[English] [Simplified Chinese] [Japanese]

P220/2015 – 14 July 2015
BEPS Action 7: OECD releases revised discussion draft on definition of permanent establishment
[English] [Simplified Chinese] [Japanese]

P219/2015 – 26 June 2015
BEPS Action 13: Country-by-country reporting implementation package
[English] [Simplified Chinese] [Japanese]

P218/2015 – 19 June 2015
BEPS Action 8: OECD issues discussion draft on hard-to-value intangibles
[English] [Simplified Chinese] [Japanese

P217/2015 – 18 May 2015
Individual income tax treatment of contribution of nonmonetary assets clarified
[English] [Simplified Chinese] [Japanese]

P216/2015 – 13 May 2015
BEPS Action 8: OECD releases draft guidance on cost contribution arrangements
[English] [Simplified Chinese] [Japanese]

H63/2015 – 12 May 2015
Update on proposed Hong Kong profits tax exemption for private equity funds
[English] [Simplified Chinese

H62/2015 – 21 April 2015
New protocol for Hong Kong-China double taxation arrangement signed
[English] [Simplified Chinese]

P215/2015 – 9 April 2015
SAT releases new bulletin to strengthen Transfer Pricing administration on Intra-group outbound charges 
[English] [Simplified Chinese] [Japanese]  

P214/2015 – 11 March 2015
China-Korea Free Trade Agreement – One of the most popular potential FTA
[English] [Simplified Chinese

H61/2015 – 25 February 2015
2015/16 Budget Analysis: Comprehensive budget with diverse initiatives but housing measures are fewer than expected
[English] [Simplified Chinese] [Traditional Chinese]

P213/2015 – 13 February 2015
BEPS Action 13: OECD issues guidance on CbC reporting implementation
[English] [Simplified Chinese] [Japanese

P212/2015 – 6 February 2015
SAT issues new rules on indirect transfers of assets by nonresident enterprises
[English] [Simplified Chinese] [Japanese

P211/2015 – 4 February 2015
BEPS Action 10: Discussion draft on the use of profit splits in the context of global value chains
[English] [Simplified Chinese] [Japanese]  

P210/2015 – 30 January 2015
BEPS Actions 8, 9, and 10: Discussion draft on revisions to chapter I of the transfer pricing guidelines (including risk, recharacterization, and special measures)
[English] [Simplified Chinese] [Japanese]  

P209/2015 – 23 January 2015
BEPS Action 14: Make dispute resolution mechanisms more effective
[English] [Simplified Chinese] [Japanese

P208/2015 – 21 January 2015
BEPS Action 4: Discussion draft released on deductibility of interest expense
[English] [Simplified Chinese] [Japanese]

P207/2015 – 19 January 2015
BEPS Action 10: Discussion draft on the transfer pricing aspects of cross-border commodity transactions
[English] [Simplified Chinese] [Japanese]

P206/2014 – 16 January 2015
OECD Issues BEPS Transfer Pricing Discussion Drafts
[English] [Simplified Chinese] [Japanese

H60/2015 – 13 January 2015
Hong Kong courts rule lump sum received on termination of contract not taxable
[English] [Simplified Chinese

Year 2014

P205/2014 – 30 December 2014
SAT issues guidance on tax treatment of share transfers by individuals
[English] [Simplified Chinese] [Japanese

P204/2014 – 29 December 2014
China tariff policy for 2015 announced
[English] [Simplified Chinese] [Japanese]  

P203/2014 – 19 December 2014
SAT issues regulations on the application of the GAAR 
[English] [Simplified Chinese] [Japanese]

P202/2014 – 14 November 2014
BEPS Action 10:  Proposed modifications to transfer pricing guidelines relating to low value-adding intragroup services
[English] [Simplified Chinese] [Japanese]

P201/2014 – 7 November 2014
BEPS Action 7: Preventing the artificial avoidance of PE status
[English] [Simplified Chinese] [Japanese]

P200/2014 – 15 October 2014
BEPS Action 2: Hybrid mismatch arrangements
[English] [Simplified Chinese] [Japanese]

P199/2014 – 29 September 2014
OECD Release on Intangibles: Many issues unanswered
[English] [Simplified Chinese] [Japanese]

P198/2014 – 29 September 2014
OECD releases the BEPS Project 2014 deliverables
[English] [Simplified Chinese] [Japanese

P197/2014 – 29 September 2014
OECD Chapter I Release: Important guidance on location-specific advantages and passive association
[English] [Simplified Chinese] [Japanese]

P196/2014 – 26 September 2014
BEPS Action 15: Developing a multilateral instrument to modify bilateral tax treaties
[English] [Simplified Chinese] [Japanese]

P195/2014 – 25 September 2014
BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances
[English] [Simplified Chinese] [Japanese]

P194/2014 – 24 September 2014
OECD Release on Transfer Pricing Documentation: The new global standard
[English] [Simplified Chinese] [Japanese]

H59/2014 – 6 August 2014
Hong Kong signs first tax information exchange agreement
[
English] [Simplified Chinese]

P193/2014 – 11 July 2014
Transfer Pricing and ‘High and New Technology Enterprises’ in China: What you need to know
[English] [Simplified Chinese] [Japanese]

H58/2014 – 16 June 2014
Proposal to extend Hong Kong’s offshore fund exemption to private equity: A step in the right direction
[English] [Simplified Chinese]

P192/2014 – 21 May 2014
BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances
[English] [Simplified Chinese] [Japanese]

P191/2014 – 13 May 2014
BEPS Action 2: Hybrid mismatch arrangements
[English] [Simplified Chinese] [Japanese]

P190/2014 – 12 May 2014
BEPS Action 1: Tax challenges of the digital economy
[English] [Simplified Chinese] [Japanese]

H57/2014 – 25 March 2014
Hong Kong’s new Companies Ordinance creates opportunities for tax-free amalgamations
[English] [Simplified Chinese] [Japanese]

H56/2014 - 17 March 2014
Newly published advance ruling takes a hard line in determining the locality of profits
[English] [Simplified Chinese] [Japanese]

H55/2014 - 26 February 2014
2014/15 Hong Kong Budget Analysis: Visionary budget, cutting down "sweeteners" and few tax measures for individuals
[English] [Simplified Chinese] [Japanese]

H54/2014 - 26 February 2014
2014/2015 Hong Kong SAR Budget Highlights - Summary of allowances, deductions & tax rates
[English] [Simplified Chinese] [Japanese]

P189/2014 - 29 January 2014
New China-UK tax treaty enters into force
[English] [Simplified Chinese] [Japanese]

Year 2013

H53/2013 - 20 December 2013
Update on Inland Revenue Department's views on tax treatment of share-based payment transactions: Opportunities and uncertainties
[English] [Simplified Chinese] [Japanese]

P188/2013 - 19 December 2013
MOF and SAT issue new VAT reform rules
[English] [Simplified Chinese] [Japanese]

H52/2013 - 22 November 2013
Hong Kong CFA holds unrealized gains not chargeable to profits tax
[English] [Simplified Chinese] [Japanese]

P187/2013 - 9 October 2013
SAT issues guidance on application of VAT exemption treatment
[English] [Simplified Chinese] [Japanese]

P186/2013 - 27 September 2013
China (Shanghai) Pilot Free Trade Zone: Open for Business
[English] [Simplified Chinese] [Japanese]

P185/2013 - 6 September 2013
SAT issues guidance on application of zero-rated VAT treatment
[English] [Simplified Chinese] [Japanese]

H51/2013 - 22 August 2013
Development of Islamic finance in Hong Kong
[English] [Simplified Chinese]

P184/2013 - 26 July 2013
China relaxes foreign exchange procedures on outbound payments for trade in services
[English] [Simplified Chinese] [Japanese]

P183/2013 - 3 June 2013
MOF and SAT issue new regulations on nationwide implementation of VAT reform on transportation and modern services sectors
[English] [Simplified Chinese] [Japanese]

P182/2013 - 27 May 2013
New Guidance Clarifies IIT Treatment of POst-Acquitsition Capitalization of Undistributed Profits or Reserves
[English] [Simplified Chinese

P181/2013 - 17 May 2013
SAT clarifies when a secondment arrangement creates a PE
[English] [Simplified Chinese] [Japanese]

P180/2013 - 8 May 2013
SAT issues guidance on beneficial ownership of dividends under tax arrangement with Hong Kong
[English] [Simplified Chinese] [Japanese

H50/2013 – 27 February 2013
2013/14 Budget Analysis: Compassionate, pragmatic and cautious with clear positioning of Hong Kong
[English] [Simplified Chinese] [Japanese]

P179/2013 - 4 February 2013
SAT further clarifies EIT filing requirements for enterprises with branches
[English] [Simplified Chinese] [Japanese]

P178/2013 - 24 January 2013
SAT updates guidance on application of capital gains article in China’s tax treaties
[English] [Simplified Chinese] [Japanese]

P177/2013 –17 January 2013
SAFE simplifies rules on administration of foreign exchange for direct investment
[English] [Simplified Chinese] [Japanese]

H49/2013 – 4 January 2013
Hong Kong court disallows deduction for manufacturing assets used in China
[English] [Simplified Chinese] [Japanese]

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