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.
South Private Clients and Family Office Tax Leader, PwC Hong Kong
Tel: +[852] 2289 3816