WebFeb 25, 2024 · Under section 20AN(2)(c) of the IRO, an OFC is exempted from payment of profits tax if the profits are earned from transactions in assets of a class that is not specified in Schedule 16C to the IRO (“non-Schedule 16C class”). However, profits tax exemption is inapplicable where the OFC carries on a direct trading or direct business ... WebThe key provisions of the Bill amend section 16(1)(c) and introduce the new section 16(1)(ca) to the IRO. Amendment to section 16(1)(c) Section 16(1)(c) is a double tax relief provision which is relatively limited in its application. It only applies in respect of certain interest income and gains on debt instruments that are deemed taxable ...
Hong Kong Tax Analysis - Deloitte
WebApr 28, 2024 · The Bill would enact section 16 (1) (ca), under which the existing deduction available for foreign tax paid under section 16 (1) (c) will be expanded to include foreign tax paid with respect to “specified tax”, which basically means a tax imposed by a foreign territory (whether or not a DTA territory) that is charged on a taxpayer’s gross income … Web16C to the IRO • Shares of, or comparable interests in, a special purpose entity (SPE) or interposed SPE solely holding (whether directly or indirectly) and administering one or … inanimate insanity bow fart
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WebApr 1, 2024 · allowable for deduction under section 16(1) of the IRO. Specifically, revised DIPN 28 states that “foreign taxes on profits or income (e.g., withholding tax on royalties, licensing fees, service fees and management fees), subject to the provisions in section 16(1)(c), are not deductible.” The provisions in section 16(1)(c) however only allow, WebHowever, section 16(1)(c) of the IRO provides that foreign tax paid in respect of certain specified interest, gains and profits. 1. are deductible. While section 16(1)(c) does not allow deduction for foreign tax charged on income other than those specified, it was the general prevailing practice for taxpayer to claim deduction under section 16 ... WebSection 70 of the Inland Revenue Ordinance states that assessments are to be final and conclusive for all purposes of the Ordinance. That is a sweeping and draconian section. It is clear that section 70A was introduced to overc ome the possible hardship of section 70. Section 70A is limited to correcting errors or omissions in inch to mm chart fractions