News & Insights

Tax Seminar: Advance Rulings – Decline and Fall?

Deacons is pleased to host a practical, incisive, and strategic seminar on Advance Ruling applications.

Advance Ruling applications are submissions made to the IRD asking it to decide how tax law will apply to the specified arrangement or transaction. In this way, applicants can seek IRD ‘clearance’ on a question of tax law. A favourable ruling can provide applicants with legal certainty and comfort on the Hong Kong tax implications of a structure before it is implemented and so manage the risk of future disputes with the IRD.

But for all its elegance and simplicity, the Advance Ruling regime hides traps and pitfalls for the unwary and the unprepared.

Drawing upon Deacons’ extensive experience with Advance Rulings, we will:

  • Provide an overview of how Advance Rulings work – how to apply for one and manage the process.
  • Consider forensic tactics and IRD psychology – how to maximise the probability of a favourable ruling.
  • Analyse the strategic implications of Advance Rulings – what happens if the IRD issues an adverse ruling?
  • Evaluate judicial review as a solution to challenging an adverse ruling.
  • Discuss alternatives to seeking an Advance Ruling – how to implement complex or aggressive structures without surrendering the initiative to the IRD.
  • Conclude if Advance Rulings are still worthwhile, or are we living in the age of their decline and fall?



Tuesday, 4 August 2015




1:00pm – 2:00pm (registration starts at 12:30pm)




14th Floor, Alexandra House

18 Chater Road, Central










CPD Points (Law Society):


One CPD point




Camay Lau at +852 2825 9426



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