Hong Kong’s new and aggressive approach to tax treaty benefits

Travis Benjamin recently contributed an article on Hong Kong’s new and aggressive approach to tax treaty benefits in Hong Kong Lawyer, a Thomson Reuters publication.

On January 29th 2015, the Inland Revenue Department announced new, hardline procedures for obtaining a certificate of Hong Kong resident status for the purpose of Hong Kong’s comprehensive double taxation agreement network.

The new rules became effective on 1 February 2015.  In a radical departure from past practice, all companies, partnerships, and trusts claiming Hong Kong tax resident status must now annually submit to an abridged tax audit examination when making an application to the Inland Revenue Department (“IRD”) for a certificate of Hong Kong resident status.