- Deacons: Source, residence and the future of Hong Kong tax
- Distinction between territorial taxation and residence
- The expanding nexus on which profits or income are taxed
- Tax reform in Hong Kong—moving towards residence and a general income tax?
Private Client analysis: Tax law in Hong Kong is schedular and territorial. Historically, this entailed simplicity and a high degree of legal certainty. The Hong Kong Inland Revenue Department (IRD) had limited interest in activities taking place outside of Hong Kong because offshore income is in general not taxable. Nevertheless, current IRD praxis and the approach taken by the Board of Review (Board) suggest an increasingly restrictive and impressionistic approach to the territoriality principle, which should factor in to the structuring and implementation considerations of businesses operating in or through Hong Kong.
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