Hong Kong Tax Review 2017Hong Kong Tax Review 2017 2 Hong Kong became a signatory to the Multilateral Instrument Hong Kong, being represented by China, became a signatory to the MLI

Hong Kong Tax Review 2017

www.pwchk.com

Hong Kong: 2017 year in reviewWe applaud the Hong Kong Special Administrative Region (HKSAR) Government’s efforts during year 2017 in both (i) enacting/proposing various tax incentives for different industries in Hong Kong to foster Hong Kong’s economic development and (ii) taking steps to align Hong Kong’s tax system with the latest international tax standards.

To enhance the competitiveness of Hong Kong’s tax system, a concessionary tax regime for aircraft leasing businesses was enacted in 2017 and a number of tax measures have been proposed pending the enactment of the necessary legislative amendments, including (i) profits tax exemption for onshore privately offered Open-ended Fund Companies (OFCs); (ii) a two-tier profits tax system and (iii) a super tax deduction for qualifying Research and Development (R&D) expenditure.

To ensure Hong Kong complies with the latest international tax standards, the HKSAR Government is working on various pieces of draft tax legislation to implement the four minimum standards under the Base Erosion & Profit Shifting (BEPS) project as well as to expedite the expansion of Hong Kong’s network for automatic exchange of financial account information in tax matters (AEOI). Forthcoming changes expected to take place in this area include: (i) introduction of a Transfer Pricing (TP) regime and mandatory TP documentation (including Country-by-Country (CbC) reporting) requirement in Hong Kong; (ii) removing the ring-fencing feature in the existing concessionary tax regimes for corporate treasury centres, offshore reinsurance businesses and offshore captive insurance businesses; (iii) implementing the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Multilateral Convention) signed by China in Hong Kong, and (iv) legislating the Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent BEPS (the Multilateral Instrument or MLI) into the domestic law of Hong Kong.

This review recaps the major tax developments that took place in 2017 and highlights the tax changes expected to take place in early 2018. The details of most of these developments have been covered in our Hong Kong Tax News Flashes, Hong Kong Financial Services Tax News Flashes, Hong Kong Transfer Pricing News Flashes and International Assignment Services – Hong Kong Publications issued during the year.

PwC1

The bill on implementing various BEPS measures A bill that seeks to implement the following minimum BEPS standards in Hong Kong was gazetted on 29 December 2017:

• removing the ring-fencing feature exists in the current concessionary tax regimes for (i) corporate treasury centres; (ii) reinsurance businesses and (iii) captive insurance businesses (BEPS Action 5);

• introducing a TP regulatory regime and a three-tiered TP documentation (including the CbC reporting) requirement in Hong Kong (BEPS Action 13);

• putting in place a statutory dispute resolution mechanism by requiring the Commissioner of Inland Revenue (CIR) to give effect to mutual agreements made with other treaty jurisdictions under the Mutual Agreement Procedure (MAP) or arbitration process of a tax treaty (BEPS Action 14);

• clarifying the double tax reliefs available in the absence or in presence of a tax treaty;

• extending the time limit of making a fresh foreign tax credit claim from two years to six years after the end of relevant year of assessment; and

• empowering the CIR to prescribe a threshold requirement for determining whether profits producing activities are carried out in Hong Kong in respect of existing concessionary tax regimes.

The bill has to be scrutinised and approved by the Legislative Council before enacted into law.

Please refer to our Hong Kong Tax News Flash, January 2018, Issue 1 and Transfer Pricing News Flash, December 2017 for a more detailed discussion of the bill.

Progress of implementing the BEPS measures in Hong Kong

https://www.pwchk.com/en/services/tax/publications/hongkongtax-news-jan2018-1.html

https://www.pwchk.com/en/services/tax/publications/transfer-pricing-legislation-comes-to-hk.html


Hong Kong Tax Review 2017 2

Hong Kong became a signatory to the Multilateral Instrument Hong Kong, being represented by China, became a signatory to the MLI at the signing ceremony held by the Organisation for Economic Cooperation and Development (OECD) on 7 June 2017. The MLI will help modify bilateral tax treaties more swiftly and thus facilitate the implementation of the treaty-related measures in countering BEPS.

In implementing the MLI, the HKSAR Government has only opted for those provisions that represent the minimum BEPS standards (e.g. the principal purposes test and the minimum three-year period for taxpayers to initiate the MAP) and has opted out of the other provisions that are not mandatory.

The HKSAR Government plans to introduce a bill relating to the MLI to the Legislative Council in mid-2018.

Please refer to our Hong Kong Tax News Flash, June 2017, Issue 6 for a more detailed discussion on Hong Kong’s MLI position.

https://www.pwchk.com/en/services/tax/publications/hongkongtax-news-jun2017-6.html

PwC3

Update on Hong Kong tax treaty network

JurisdictionDate of signing

Date of entry into force

Effective date in Hong Kong (year of assessment)

Effective date in the other contracting jurisdiction

Belarus January 2017 November 2017 2018/19 1 January 2018

Latvia April 2016 November 2017 2018/19 1 January 2018

Pakistan February 2017 November 2017 2018/19 1 July 2018

Saudi Arabia August 2017 Pending Pending Pending

In addition, the second protocol to the Hong Kong-New Zealand tax treaty was signed by Hong Kong on 15 June 2017 and by New Zealand on 28 June 2017 to allow both parties to exchange information on an automatic or a spontaneous basis.

Looking into 2018, it is expected that Hong Kong will sign a few more tax treaties with its trading partners. One of them will be the Hong Kong-India tax treaty which is expected to be signed soon as the approval process of the treaty in India has recently been completed.

Another treaty-related development in 2017 is the revised regulations for claiming treaty benefits in Indonesia. Under the revised rules, which apply from 1 August 2017, the major hurdle (i.e., the “subject to tax” requirement) for Hong Kong tax residents to apply the Hong Kong-Indonesia tax treaty has been removed. For more details and other changes introduced by the revised regulations, please refer to our Hong Kong Tax News Flash, July 2017, Issue 9.

Hong Kong signed three new tax treaties during 2017, bringing the total number of Hong Kong tax treaties to 38 as of December 2017. In addition, the tax treaties with Latvia (signed in 2016) as well as Belarus and Pakistan (both signed in 2017) entered into force in 2017. Please refer to the table below for more details of these tax treaties.

https://www.pwchk.com/en/services/tax/publications/hongkongtax-news-jul2017-9.html


The HKSAR Government held the “Summit on the New Directions for Taxation” on 23 October 2017 to explore the new directions for taxation in Hong Kong. At the summit, the Financial Secretary revealed that the current administration will adhere to the following four principles in formulating future tax policies and measures:

The tax summit on new directions for taxation

With these four key principles, we look forward to seeing more supportive tax policies/measures that will assist Hong Kong companies to better capture new business opportunities, particularly related to China’s Belt and Road Initiative.

Please refer to our Hong Kong Tax News Flash, October 2017, Issue 11 for more details of the tax summit.

the tax measures should be targeted (i.e., tailor-made for specific industries)

the tax measures should be able to generate considerable economic and social benefits

the tax measures must be simple and easy to operate so as to allow Hong Kong to maintain the existing simple and low tax regime, but yet with manageable risks of tax avoidance

the tax measures must be able to meet the international tax standards

https://www.pwchk.com/en/services/tax/publications/hongkongtax-news-oct2017-11.html

PwC5

Key tax legislative developments in 2017

The table below summarises the tax legislation enacted in 2017:

Legislation Key subject matter Effective date

1. Inland Revenue (Amendment) Ordinance 2017 (enacted on 2 June 2017)

• Implementing the tax measures proposed in the 2017/18 Hong Kong Budget, including:

– A 75% tax rebate for year of assessment 2016/17, subject to a ceiling of HK$20,000

– Widening the marginal tax bands for salaries tax purposes from HK$40,000 to HK$45,000

– Increase in certain personal allowances and self-education expense deduction ceiling for salaries tax purposes

For more details of the other budget proposals, please visit our website dedicated to the 2017/18 Hong Kong Budget1.

2. Inland Revenue (Amendment) (No.2) Ordinance 2017 (enacted on 16 June 2017)

• Adding 73 jurisdictions to the list of reportable jurisdictions of Hong Kong (in addition to Japan and the UK which are already in the list) for the AEOI purpose fullstop.

1 July 2017

3. Inland Revenue (Amendment) (No.3) Ordinance 2017 (enacted on 7 July 2017)

• Introducing a concessionary tax regime for qualifying aircraft leasing businesses and qualifying aircraft leasing management businesses in Hong Kong

• Introducing a provision to deem the profits derived from carrying on an aircraft leasing business or an aircraft leasing management business in Hong Kong to be chargeable to profits tax even if the aircraft concerned is used outside Hong Kong.

Please refer to our Hong Kong Tax News Flash, March 2017, Issue 4 and Hong Kong Financial Services Tax News Flash, May 2017 for more details of the new tax regime.

1 April 2017

7 July 2017

1 www.pwchk.com/en/services/tax/hkbudget2017.html

Year of assessment 2016/17



https://www.pwchk.com/en/services/tax/publications/hongkongtax-news-mar2017-4.html


https://www.pwchk.com/en/industries/financial-services/publications/fstax-news-may2017-1.html



Bill Key subject matter Gazettal date

1. Inland Revenue (Amendment) (No.4) Bill 2017

• Extending the profits tax exemption for offshore investment funds to onshore privately offered OFCs, subject to specified conditions

Please refer to our Hong Kong Financial Services Tax News Flash, June 2017 for more details of the bill.

23 June 2017


• Enabling Hong Kong to adopt the Multilateral Convention signed by China and other agreements on international tax cooperation that apply to Hong Kong

• Amending certain IRO provisions on AEOI so that they align with the international standard stipulated by the OECD

6 October 2017


• Implementing various BEPS measures that represent the minimum standards in Hong Kong (please refer to the section “Progress of implementing the BEPS measures in Hong Kong” above)

Please refer to our Hong Kong Tax News Flash, January 2018, Issue 1 for a more detailed discussion of the bill.

29 December 2017


• Introducing a two-tier profits tax system in Hong Kong under which the first HK$2 million of assessable profits will be taxed at 8.25% (for corporations) or 7.5% (for unincorporated businesses)

Please refer to our Hong Kong Tax News Flash, December 2017, Issue 13 for a more detailed discussion of the bill.

29 December 2017

5. Stamp Duty (Amendment) Bill 2017

• Introducing a flat rate of 15% for the ad valorem stamp duty (AVD) chargeable on residential property transactions executed on or after 5 November 2016, in lieu of the existing Scale 1 rates (i.e., the doubled AVD rates), with certain exceptions

27 January 2017

6. Stamp Duty (Amendment) (No.2) Bill 2017

• Extending the 15% flat AVD rate to acquisition of more than one residential property under one instrument by Hong Kong permanent residents on or after 12 April 2017

26 May 2017

The table below summarises the draft tax legislation pending enactment as of the end of 2017:

Other tax proposals under considerationIn addition to the above, the HKSAR Government has proposed the following tax measures of which the related draft tax legislation is expected to be issued soon:

• Introducing a 300% tax deduction for the first HK$2 million of qualifying R&D expenditure incurred by enterprises and 200% tax deduction for the remaining expenditure.

• Expanding the scope of tax deduction for capital expenditure incurred for the purchase of intellectual property rights to layout-design of integrated circuits, plant varieties and rights in performance as proposed in the 2016/17 Hong Kong Budget2.

2 www.pwchk.com/en/publications/20162017-hong-kong-budget.html

https://www.pwchk.com/en/industries/financial-services/publications/fstax-news-jun2017-3.html




https://www.pwchk.com/en/services/tax/publications/hongkongtax-news-dec2017-13.html


PwC7

Guidance Key subject matter Date of issuance

1. Departmental Interpretation and Practice Notes (DIPN) No.53

• Setting out the IRD’s views, with numerous illustrative examples, on the profits tax treatment of regulatory capital securities issued by financial institutions in compliance with Basel III capital adequacy requirements

22 February 2017

2. DIPN No.54 • Setting out the IRD’s views on the interpretation and application of the various provisions of the concessionary tax regime for the aircraft leasing businesses in Hong Kong

27 October 2017

3. Revised guidance on corporate amalgamation

• Providing further guidance on the utilisation of tax losses of amalgamating companies and amalgamated companies respectively

16 December 2016

The table below summarises the guidance issued by the IRD in late 2016 and during 2017:

Guidance issued by the Inland Revenue Department (IRD)


The Perfekta Enterprises case The Court of First Instance (CFI) held on 27 April 2017 that the initial payment received by the taxpayer for co-developing with a land developer a piece of land originally acquired by the taxpayer as a capital asset is revenue in nature and taxable. The court found that there was a change of the taxpayer’s intention from capital holding to trading when the taxpayer entered into the redevelopment agreement with the land developer and before the transfer of the subject land to its subsidiary for carrying out the redevelopment. The taxpayer has subsequently lodged an appeal against the CFI’s judgment to the Court of Appeal (COA), which will be heard on 11 April 2018.

Please refer to our Hong Kong Tax News Flash, June 2017, Issue 5 for a more detailed discussion of the case and our comments.

Board of Review Case D2/16 (published in April 2017)In this case, the Board held that the trading profits derived by a Hong Kong company (which entered into an import processing arrangement with its wholly owned subsidiary in China) from the sale of finished goods to its customers in China were sourced in Hong Kong. In addition, the Board concluded that in the absence of a primary TP adjustment made by a tax treaty partner (i.e., the Chinese tax authority in this case), no unilateral TP adjustment can be made to reduce the taxpayer’s allegedly inflated Hong Kong sourced profits despite the taxpayer claimed that the profits were not stated on an arm’s length basis.

Please refer to our Hong Kong Tax News Flash, June 2017, Issue 7 for a detailed discussion of the Board’s decision and our comments.

Update on Hong Kong profits tax cases



PwC9

Hong Kong salaries tax developments

Increase in certain personal allowances and changes to concessionary deductions The 2017/18 Budget delivered on 22 February 2017 proposed to:

All of the above salaries tax proposals were enacted into law in June 2017 and are effective from year of assessment 2017/18.

Please refer to our International Assignment Services – Hong Kong Publication, March 2017 for a more detailed discussion of the salaries tax measures in the 2017/18 Budget.

widen the marginal tax bands from HK$40,000 to HK$45,000 for salaries tax purposes increase certain

personal allowances and the self-education deduction ceiling

extend the entitlement period for home loan interest deduction to 20 years

https://www.gmsasia.pwc.com/en/publications/hk-budget-news-mar2017.html


Update on salaries tax court cases• The Poon Cho-ming case

In Hong Kong Tax Review 20163, we reported that the CFI held in this case that (1) payment in lieu of a discretionary bonus made to the taxpayer and (2) stock option gains derived by the taxpayer from the accelerated vesting of certain previously granted options upon termination of his employment were income from employment and subject to salaries tax despite such payment and accelerated vesting were not provided for in the taxpayer’s employment contract.

Subsequently, the taxpayer has appealed against the CFI’s judgment to the COA. The appeal was heard on 16 May 2017 but the judgment has yet to be published.

• The Pang Fai case

The case concerned whether a sum described as “honorarium” received by an individual from an accounting professional body for acting as a workshop facilitator and examination marker should be assessed under salaries tax or profits tax.

The Board held in Case D11/16 that it was inapt to apply either the “economic reality test” or the “control test” to determine whether an employer-employee relationship existed between the individual and the professional body. By making a macro holistic evaluation of all the facts together, the Board held that the individual was not an employee and the amount should be chargeable to profits tax. The Commissioner of Inland Revenue (CIR) appealed against the Board’s decision to the CFI.

The CFI dismissed the CIR’s appeal by a judgment handed down on 3 November 2017. It held that as the Board did not misdirect itself in law or reach a conclusion that no tribunal properly directing itself on the relevant facts could reasonably have reached, it is not justifiable for the court to interfere in the Board’s conclusion that the taxpayer was not an employee of the professional body.

3 Hong Kong Tax Review 2016 can be accessed via this link: https://www.pwchk.com/en/services/tax/publications/hongkong-tax-review-dec2016.html

PwC11

List of Hong Kong Tax News Flashes issued in 2017 and early 2018

The IRD’s latest comments on corporate amalgamation and other profits tax issues


The IRD commented on issues related to tax treaty application


Hong Kong revises its strategy on implementing automatic exchange of financial account information

https://www.pwchk.com/en/services/tax/publications/hktax-news-mar2017-3.html

Hong Kong ready for the buoyant aircraft leasing market with the new tax regime


Receipt for entering into a co-redevelopment of a piece of land is found to be revenue in nature


Hong Kong reaffirming its stance against treaty abuse by being a signatory to the Multilateral Instrument


Downward transfer pricing adjustment is only possible in the presence of a primary adjustment by a treaty partner


Implementing automatic exchange of financial account information in Hong Kong – The AEOI Portal


The new Indonesian rules remove a major hurdle for Hong Kong tax residents to apply the HK-Indonesia tax treaty


New tax measures to take Hong Kong’s economy to greater heights


New directions for taxation were discussed in the first ever government-held tax summit


Hong Kong is not on the EU blacklist with its commitment to comply with the international tax standards


SMEs will benefit from the new two-tier profits tax system


Hong Kong Government issued the Bill on BEPS actions



List of Transfer Pricing News Flashes issued in 2017

List of Hong Kong Financial Services Tax News Flashes issued in 2017

List of International Assignment Services - Hong Kong Publications issued in 2017

Hong Kong SAR Government’s Roadmap following the outcomes of the BEPS Consultation

https://www.pwchk.com/en/services/tax/publications/hong-kong-sar-government-roadmap-beps-consultation.html

Transfer pricing legislation comes to Hong Kong


The proposed dedicated tax regime for aircraft leasing business in Hong Kong

https://www.pwchk.com/en/industries/financial-services/publications/fstax-news-feb2017.html

Bill on the concessionary tax regime for aircraft leasing considered by the Legislative Council

https://www.pwchk.com/en/industries/financial-services/publications/fstax-news-apr2017.html

The Hong Kong SAR Government has proposed to introduce Committee Stage Amendments to extend the concessionary tax regime to onshore aircraft leasing activities


HKSAR Government’s responses to key issues raised by deputations for Aircraft Leasing and Financing


The Tax Bill on privately offered Hong Kong open-ended fund companies regime gazette


Newly launched Northbound trading of Bond Connect calls for specific taxation regulation

https://www.pwchk.com/en/industries/financial-services/publications/fstax-news-jul2017.html

Private equity funds in Qianhai welcome new QFLP schemes

https://www.pwchk.com/en/industries/financial-services/publications/fstax-news-nov2017.html

Hong Kong: 2017/18 budget proposes changes to salaries tax

https://www.gmsasia.pwc.com/en/publications/hk-budget-news-mar2017.html

Hong Kong: The IRD’s recent comments on various salaries tax issues

https://www.gmsasia.pwc.com/en/publications/hk-irds-news-mar2017.html

Hong Kong: The Court of Appeal’s judgment on dependent visas for same-sex couples

https://www.gmsasia.pwc.com/en/publications/hk-same-sex-couples-sep2017.html

PwC13

Contact listOur leaders

Asia Pacific and Greater China Chairman Raymund Chao +852 2289 2111

Head of Tax — Mainland China, Hong Kong, Singapore and Taiwan Peter Ng +852 2289 1828

China South and Hong Kong Tax Leader Charles Lee +852 2289 8899

China South Tax Leader Jeremy Ngai +852 2289 5616

Our tax contacts in Hong Kong

Hong Kong Profits Tax / International Tax

* Agnes Wong (Transportation and Logistics)

+852 2289 3816

* Florence Yip (Financial Services, Asset and Wealth Management)

+852 2289 1833

* Gwenda Ho (Technology, Media and Telecommunication)

+852 2289 3857

* Jenny Tsao (Corporate Tax and Retail and Consumer)

+852 2289 3617

*Jeremy Choi (Industrial Products) +852 2289 3608

*KK So (Real Estate) +852 2289 3789

*Rex Ho (Financial Services) +852 2289 3026

* Suzanne Wat (Common Reporting Standards and Tax Reporting and Strategy)

+852 2289 3002

Accounting and Payroll

*Peggy Cheng +852 2289 1406

China Corporate Tax

*Catherine Tsang (Real Estate) +852 2289 5638

* Cathy Jiang (Transportation and Logistics)

+852 2289 5659

*Jeremy Ngai (Mergers and Acquisitions) +852 2289 5616

Company Secretarial

*Loretta Chan +852 2289 6700

Customs / Duties

Derek Lee +86 (755) 8261 8218

Global Mobility

*James Clemence +852 2289 1818

Personal Financial Services

*John Wong + 852 2289 1810

Tax Controversy

*Kenneth Wong +852 2289 3822

Tax Technology

Ann Kwok +852 2289 3808

Transfer Pricing

Cecilia Lee +852 2289 5690

*Colin Farrell +852 2289 3800

Phillip Mak (Financial Services) +852 2289 3503

US Tax Consulting

*Wendy Ng +852 2289 3933

Our Senior Tax Advisors in Hong Kong

Anthony Tong +852 2289 3939

David Smith +852 2289 5802

Tim Lui +852 2289 3088

Tiang & Co.#

Legal

David Tiang +852 2833 4928

*Joseph Tse +852 2833 4933

* Practice Unit/Industry Tax Leader# Tiang & Co. is associated with PwC Legal International Pte Ltd (a

licensed Foreign Law Practice) in Singapore

Tiang & Co. is an independent Hong Kong law firm. Neither Tiang & Co. nor PwC Legal International Pte Ltd has any control over, or acts as an agent of, or assumes any liability for the acts or omissions of, the other.


Our regional contacts

Beijing

Edwin [email protected]

+86 (10) 6533 2100

Changsha

Collin [email protected]

+86 (755) 8261 8280

Chengdu

William [email protected]

+86 (28) 6291 2018

Chongqing

Robert [email protected]

+86 (21) 2323 2596

Dalian

Rex [email protected]

+86 (10) 6533 2022

Guangzhou

Ingrid Qin [email protected]

+86 (20) 3819 2191

Hangzhou

Jeffrey Qian / Jenny [email protected]@cn.pwc.com

+86 (571) 2807 6318+86 (21) 2323 3219

Hefei

Alan [email protected]

+86 (21) 2323 2518

Hong Kong

Charles [email protected]

+852 2289 8899

Jinan

Edwin [email protected]

+86 (10) 6533 2100

Kunming

Ingrid [email protected]

+86 (20) 3819 2191

Macau

Grace [email protected]

+ 853 8799 5121

Nanjing

Benny Zhang / Jane [email protected] / [email protected]

+86 (25) 6608 6278 / +86 (21) 2323 2896

Ningbo

Ray [email protected]

+86 (21) 2323 3071

Qingdao

Helen [email protected]

+86 (532) 8089 1815

Shanghai

Alan [email protected]

+86 (21) 2323 2518

Shenyang

Rex [email protected]

+86 (10) 6533 2022

Shenzhen

Cathy Jiang / Charles [email protected]@cn.pwc.com

+86 (755) 8261 8820+86 (755) 8261 8899

Singapore

Chris [email protected]

+65 6236 3688

Suzhou

Mike [email protected]

+86 (512) 6273 1892

Taiwan

Howard [email protected]

+886 (2) 2729 5226

Tianjin

Kelvin [email protected]

+86 (10) 6533 3068

Wuhan

Amanda Cao / Gang [email protected] /[email protected]

+86 (21) 2323 3019 / +86 (20) 3819 2566

Xiamen

Minting [email protected]

+86 (592) 210 1658

Xian

Elton Huang / Jackie [email protected] / [email protected]

+86 (21) 2323 3029 / +86 (29) 8469 2661

Zhengzhou

Yu [email protected]

+86 (10) 6533 3206

PwC15

In the context of this publication, China, Mainland China or the PRC refers to the People’s Republic of China but excludes Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan Region.

The information contained in this publication is of a general nature only. It is not meant to be comprehensive and does not constitute the rendering of legal, tax or other professional advice or service by PricewaterhouseCoopers Limited (PwC) or any other entity within the PwC network. PwC has no obligation to update the information as law and practices change. The application and impact of laws can vary widely based on the specific facts involved. Before taking any action, please ensure that you obtain advice specific to your circumstances from your usual PwC client service team or your other advisers.

The materials contained in this publication were assembled in December 2017 and were based on the law enforceable and information available at that time.

This publication is prepared by PwC National Tax Policy Services in Hong Kong and China, which comprises of a team of experienced professionals dedicated to monitoring, studying and analysing the existing and evolving policies in taxation and other business regulations in China, Hong Kong, Singapore and Taiwan. They support the PwC partners and staff in their provision of quality professional services to businesses and maintain thought-leadership by sharing knowledge with the relevant tax and other regulatory authorities, academies, business communities, professionals and other interested parties.


For more information, please contact:

Matthew MuiPartnerTel: +86 (10) 6533 [email protected]

Fergus WongDirectorTel: +852 2289 [email protected]

Anita TsangAssociate DirectorTel: +852 2289 [email protected]

Please visit our websites at http://www.pwccn.com (China Home) or http://www.pwchk.com (Hong Kong Home) for practical insights and professional solutions to current and emerging business issues.

www.pwchk.comThe materials contained in this publication were assembled in December 2017 and were based on information available at that time.

The information contained in this publication is of a general nature only. It is not meant to be comprehensive and does not constitute the rendering of legal, tax or other professional advice or service by PricewaterhouseCoopers Limited or any other entity within the PwC network.

© 2018 PricewaterhouseCoopers Ltd. All rights reserved. PwC refers to the Hong Kong member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details. HK-20171214-1-C1.

Documents

Hong Kong Tax Review 2017Hong Kong Tax Review 2017 2 Hong Kong became a signatory to the Multilateral Instrument Hong Kong, being represented by China, became a signatory to the MLI