Hong Kong–MNE Tax

Asia-Pacific

Hong Kong announces plans to implement BEPS 2.0, introduce 15% domestic minimum tax for in-scope MNCs from 2024-25: Yuen / Marketing-Interactive.com→

February 23, 2022

Americas

UK consults on introduction of corporate re-domiciliation regime

November 2, 2021

The UK government on October 27 opened a consultation on the possibility of introducing a “corporate re-domiciliation” regime to make it easier for companies to relocate to the UK while maintaining . . .

Americas

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

October 19, 2021

There are signs that the competent authorities of Brazil, Russia, and China have insufficient resources to keep up with their caseloads for resolving tax and transfer pricing disputes through mutual agreement procedure (MAP), according to peer review reports released October 18 by the OECD, while . . .

Asia-Pacific

Hong Kong plans tax changes to get off EU’s ‘gray list’

October 6, 2021

The government of Hong Kong on October 5 responded to the EU’s inclusion of Hong Kong in its updated “gray list” of jurisdictions that do not yet comply with certain international tax standards, stating that it . . .

Africa

EU removes three jurisdictions from tax ‘black list’

October 5, 2021

The European Council on October 5 approved the removal of Anguilla, Dominica, and Seychelles from the EU’s list of non-cooperative jurisdictions for tax purposes, the so-called “black list,” and moving . . .

Americas

Asia to see disparate impacts from global digital tax reforms, IMF reports

September 15, 2021

Global tax reform efforts to address digitalization of the economy would likely have modest revenue effects in Asia, on the whole, according to a September 14 report from the International Monetary Fund; however, the effects would be uneven . . .

Americas

European banks’ tax haven use persists but varies widely, study finds

September 7, 2021

Large European banks report an average of 20% of their profits in tax havens, but some report more than half of their profits in such jurisdictions while others report none, according to a September 6 report from the EU Tax Observatory . . .

Asia-Pacific

Russia looking into revising tax treaties with Switzerland, Hong Kong, and Singapore, according to government official, following three other recent treaty revisions and renunciation of Dutch treaty: Fahad Shabbir / UrduPoint News→

August 23, 2021

Asia-Pacific

Hong Kong tax agency advises on tax and transfer pricing effects of Covid-19

August 9, 2021

The Hong Kong Inland Revenue Department on July 29 clarified its approach to the disruptions caused by Covid-19 with respect to various tax issues, including issues related to tax residence, permanent establishment . . .

Africa

US FDII deduction among international ‘harmful tax practices’ slated to be abolished

August 5, 2021

An update on reviews of preferential tax regimes published by the OECD on August 5 states that the US foreign-derived intangible income (FDII) regime is “in the process of being eliminated.” The new report includes updated conclusions with respect to 18 designated . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Asia-Pacific

Hong Kong will implement international consensus on BEPS 2.0 while striving to maintain tax advantages in terms of simplicity, certainty, and fairness: Hong Kong Inland Revenue Department→

July 14, 2021

Americas

Global tax pact gains 131st country, about 80 companies would see profit reallocations

July 6, 2021

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

Asia-Pacific

Japan enacts corporate, income, inheritance tax reforms

May 26, 2021

Takato Masuda of Nishimura & Asahi discusses Japanese corporate, income, and inheritance tax reforms enacted March 26 . . .

Hong Kong proposes new rules enhancing deductibility of foreign tax

April 20, 2021

Stefano Mariani & Bernie Ng, Deacons, discuss Hong Kong’s gazetting of the Inland Revenue Bill 2021 on 19 March, seeking to expand and clarify the profits tax deductions for foreign taxes . . .

Asia-Pacific

Global minimum tax’s effect on Hong Kong could be an issue for China, support could be tied to US trade tariff concessions: Frank Tang & Orange Wang / South China Morning Post→

April 9, 2021

Asia-Pacific

Hong Kong 2021–22 budget includes one-off reductions in profits tax, salaries tax, and tax under personal assessment: Inland Revenue Department→

February 24, 2021

Asia-Pacific

Hong Kong laws granting profits tax concessions for insurance-related business and setting March 19 the law’s effective date were gazetted, government notes: Hong Kong government→

January 28, 2021

Asia-Pacific

Hong Kong, Serbia tax agreement enters into force

January 4, 2021

A comprehensive agreement providing for the avoidance of double taxation entered into force between Hong Kong . . .

Asia-Pacific

Hong Kong issues new guidance on tax concessions for ship leasing: Inland Revenue Department→

December 7, 2020

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

Americas

US to terminate international shipping agreement with Hong Kong

October 20, 2020

The US IRS, in Announcement 2020-40, has advised that the . . .

Asia-Pacific

Hong Kong adds XML schema (version 2.0) plus user guide for country-by-country reporting: Hong Kong Inland Revenue Department→

October 6, 2020

Africa

Australia to change to corporate tax residency test

October 6, 2020

The Australian government will propose to change the corporate residency test used to determine if a company incorporated offshore is liable for income tax in Australia, budget documents released today . . .

Asia-Pacific

Hong Kong, Georgia sign tax agreement lowering withholding tax rates

October 5, 2020

Hong Kong and Georgia tax officials today signed a tax agreement designed to promote . . .

Asia-Pacific

Hong Kong, Serbia enter into tax agreement

August 28, 2020

Hong Kong and Serbia have signed an agreement designed to help their residents avoid . . .

Americas

US notifies Hong Kong of intent to terminate agreement allowing international shippers to avoid double tax: US Department of State→

August 21, 2020

Asia-Pacific

Hong Kong-Macao tax arrangement enters into force

August 21, 2020

Hong Kong’s Inland Revenue Department on August 21 announced that an arrangement with Macao for the avoidance of double taxation entered into . . .

Asia-Pacific

Hong Kong updates tax guidance to reflect new laws on taxation of royalties, other IP income: Inland Revenue Department→

August 13, 2020

Asia-Pacific

Hong Kong revises transfer pricing guidance on advance pricing arrangements

July 23, 2020

Agnes Lo, Associate Professor of Teaching, Lingnan University, Hong Kong and Raymond Wong, Associate Dean, City University of Hong Kong, discuss the Hong Kong’s Inland Revenue Department’s July 15 revisions to guidance setting out the Hong Kong government’s interpretation and practice relating to advance pricing arrangements . . . .

Asia-Pacific

Hong Kong proposes one-time tax reduction

February 26, 2020

The Hong Kong budget was released today. According to Hong Kong’s . . .

Asia-Pacific

Hong Kong announces entry into force of Cambodia, Estonia tax treaties

December 30, 2019

The Hong Kong government on December 27 announced that new tax treaties with Cambodia . . .

Asia-Pacific

Hong Kong extends local entity country-by-country filing deadline

December 22, 2019

Hong Kong’s Inland Revenue Department on December 19 announced . . .

Asia-Pacific

Hong Kong proposes tax cut for insurance-related businesses

December 9, 2019

The Hong Kong government on December 6 published a bill proposing to reduce . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin

Hong Kong

Hong Kong announces plans to implement BEPS 2.0, introduce 15% domestic minimum tax for in-scope MNCs from 2024-25: Yuen / Marketing-Interactive.com→

UK consults on introduction of corporate re-domiciliation regime

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

Hong Kong plans tax changes to get off EU’s ‘gray list’

EU removes three jurisdictions from tax ‘black list’

Asia to see disparate impacts from global digital tax reforms, IMF reports

European banks’ tax haven use persists but varies widely, study finds

Russia looking into revising tax treaties with Switzerland, Hong Kong, and Singapore, according to government official, following three other recent treaty revisions and renunciation of Dutch treaty: Fahad Shabbir / UrduPoint News→

Hong Kong tax agency advises on tax and transfer pricing effects of Covid-19

US FDII deduction among international ‘harmful tax practices’ slated to be abolished

Russia’s new double tax treaty policy: the score is 3 to 1

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

Hong Kong will implement international consensus on BEPS 2.0 while striving to maintain tax advantages in terms of simplicity, certainty, and fairness: Hong Kong Inland Revenue Department→

Global tax pact gains 131st country, about 80 companies would see profit reallocations

Japan enacts corporate, income, inheritance tax reforms

Hong Kong proposes new rules enhancing deductibility of foreign tax

Global minimum tax’s effect on Hong Kong could be an issue for China, support could be tied to US trade tariff concessions: Frank Tang & Orange Wang / South China Morning Post→

Hong Kong 2021–22 budget includes one-off reductions in profits tax, salaries tax, and tax under personal assessment: Inland Revenue Department→

Hong Kong laws granting profits tax concessions for insurance-related business and setting March 19 the law’s effective date were gazetted, government notes: Hong Kong government→

Hong Kong, Serbia tax agreement enters into force

Hong Kong issues new guidance on tax concessions for ship leasing: Inland Revenue Department→

18 more nations meet global standards on countering harmful tax practices, OECD says

US to terminate international shipping agreement with Hong Kong

Hong Kong adds XML schema (version 2.0) plus user guide for country-by-country reporting: Hong Kong Inland Revenue Department→

Australia to change to corporate tax residency test

Hong Kong, Georgia sign tax agreement lowering withholding tax rates

Hong Kong, Serbia enter into tax agreement

US notifies Hong Kong of intent to terminate agreement allowing international shippers to avoid double tax: US Department of State→

Hong Kong-Macao tax arrangement enters into force

Hong Kong updates tax guidance to reflect new laws on taxation of royalties, other IP income: Inland Revenue Department→

Hong Kong revises transfer pricing guidance on advance pricing arrangements

Hong Kong government adopts tax concessions for insurance sector: Inland Revenue Revenue Department→

Hong Kong updates guidance on taxation of financial instruments, foreign exchange differentials→

Hong Kong government advances Hong Kong-Macao tax treaty: Inland Revenue Department→

Hong Kong revises guidance on advance tax rulings

Hong Kong proposes one-time tax reduction

Hong Kong announces entry into force of Cambodia, Estonia tax treaties

Hong Kong extends local entity country-by-country filing deadline

Hong Kong proposes tax cut for insurance-related businesses