Hong Kong Tax News Flash

Jan 2024, Issue 2

IRD publishes first advance ruling and further guidance on family office tax concession

The Inland Revenue Department (IRD) published its first advance ruling on the applicants’ eligibility for the tax concessions for family-owned investment holding vehicles and the tax treatment of specified foreign-sourced income received by the applicants under the foreign-sourced income exemption regime. It is of interest to note that the IRD provides detailed commentary elaborating the basis of its ruling. The detailed explanation serves as useful guidance for taxpayers seeking to enjoy the tax concession.

At the same time, the IRD also updated its online guidance on the tax concession to provide further details on the substantial activities requirement and information required for the application for an advance ruling.

This news flash discusses the ruling and the additional provided by the IRD, as well as our observations thereon.

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Agnes Wong

South Private Clients and Family Office Tax Leader, PwC Hong Kong

Tel: +[852] 2289 3816

Charles Lee

Managing Partner - Tax, PwC China

Tel: +[852] 2289 8899

Jeremy Ngai

China South Tax Leader, PwC Hong Kong

Tel: +[852] 2289 5616

Jeremy Choi

Partner, PwC Hong Kong

Tel: +[852] 2289 3608

Rex Ho

Asia Pacific Financial Services Tax Leader, PwC Hong Kong

Tel: +[852] 2289 3026

Cecilia Lee

Partner, PwC Hong Kong

Tel: +[852] 2289 5690

Jenny Tsao

Consumer Markets Tax Leader, PwC Hong Kong

Tel: +[852] 2289 3617

Kenneth Wong

Hong Kong Tax Controversy Services Leader, PwC Hong Kong

Tel: +[852] 2289 3822

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