香港稅務快訊

中審眾環(香港)對有關香港稅法的評論。

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2015年12月刊 - 香港建議為公司財務中心提供稅收優惠

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As reported in our 2015-2016 Hong Kong Budget News issued in February 2015, in order to enhance Hong Kong’s attractiveness as a Corporate Treasury Centre to multinational corporations, the Financial Secretary announced that the Government would amend the Inland Revenue Ordinance (“IRO”) to provide tax incentives for corporate treasury centres (“CTCs”) in Hong Kong by introducing a concessionary profits tax rate for qualifying profits derived by a qualifying CTC, and allowing interest expense deductions on monies borrowed from non-Hong Kong associated corporations carrying out intra-group financing business. The relevant provisions are set out in the Inland Revenue (Amendment) (No. 4) Bill 2015 (“the Bill”) which was gazatted on 4 December 2015. (1)

The Bill has been introduced into the Legislative Council (“LegCo”) on 16 December 2015 for scrutiny and approval. Upon enactment of the Bill, the relevant tax provisions will apply from 1 April 2016.

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2015年10月刊 - 公認條款下許可證費的可徵稅性

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In May 2015, the Court of Appeal (“CoA”) handed down its judgment in Turner Entertainment Networks Asia, Inc. (“Turner”) for Muse Communications Co.,Ltd (“Muse”) v. the Commissioner of Inland Revenue(“CIR”) that license fees received by a non-Hong
Kong resident, Muse, for granting rights to a Hong Kong taxpayer, Turner, to exhibit television programs outside Hong Kong are chargeable to tax in Hong Kong.

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2014年3月刊 - 香港簽訂第一份稅務信息交換協議

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Hong Kong (“HK”) has just signed an agreement for Exchange of Information (“EoI”) with the United States of America (“US”) on 25 March 2014.

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2014年1月刊 - 2014/2015瑪澤預算案

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Mazars submitted its 2014/2015 Hong Kong Budget Proposal to the Financial Secretary on 10 January 2014.

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2014年2月刊 - 稅收優惠促使香港成為專屬自保保險人的潛在居所

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In Hong Kong, a captive insurer is defined under the Insurance Companies Ordinance as an insurer which carries on general business only and is restricted to underwriting insurance and reinsurance of risks of the companies within the same group of companies to which the captive insurer belongs.

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2015年5月刊 - 與南非和阿聯酋簽訂全面性避免雙重課稅協定

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BACKGROUND

On 15 May 2015, 2 orders made by the Chief Executive were gazetted to implement the Comprehensive Agreements for the Avoidance of Double Taxation (“CDTAs”) with South Africa and the United Arab Emirates (“UAE”) that were signed in October 2014 and November 2014 respectively.

The CDTAs will enter into force after both Hong Kong and the treaty partners have completed their ratification procedures.

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2015年4月刊 - 香港建議將離岸基金免稅擴展至私募股權

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Hong Kong is a major international financial centre (“IFC”). Financial service industry is one of the four pillar industries which have been a driving force of Hong Kong’s economic growth for years. Fund and asset management business is an important component and a fast- growing area in financial service industry.

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