Not applicable for this jurisdiction.
Advance rulings are available to taxpayers as a paid service and are subject to certain formalities.
A taxpayer can voluntarily request for a ruling in specified areas, such as the application of the locality of profits rules or the general anti-avoidance provision, royalty payments, stock borrowing or lending and interest income exemption.
The normal processing time is 6 weeks, but a complex application can take significantly more time. A ruling is final, but it does not affect the taxpayer's right of objection against a subsequent tax assessment issued in accordance with an unfavorable ruling.
See Tax rates. The Revenue (Tax Concessions) Ordinance 2022 was azette on April 14, 2022 to give effect to a one-off reduction of the final tax in respect of profits tax, salaries tax and tax under personal assessment for the year of assessment 2021-22 proposed by the Financial Secretary in the 2022-23 Budget by 100 percent, subject to a ceiling of HKD10,000 per case. The Inland Revenue (Amendment) (Tax Deductions for Domestic Rents) Ordinance 2022, azette on June 30, 2022, also gave effect to the tax deduction for eligible domestic rental expenses from the year of assessment 2022-23 proposed by the Financial Secretary. Taxpayers liable to salaries tax or tax charged under personal assessment who do not own any domestic property can claim deduction for the rent paid by themselves or their spouse as the tenant, subject to an annual ceiling of HKD100,000.
The Inland revenue (Amendment) (Tax Concessions for Certain Shipping-related Activities) Ordinance 2022 was azette on July 22, 2022 and introduces half-rate profits tax concessions (ie, 8.25 percent) to qualifying shipping commercial principals, including ship agents, ship managers and ship brokers. Tax concessions will apply to sums received by or accrued to shipping commercial principals on or after April 1, 2022.
The Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Bill 2022 was gazetted on December 9, 2022 and was introduced into the Legislative Council on December 14, 2022. As an incentive for developing family office businesses in Hong Kong, the Bill aims to provide tax concessions for (a) eligible family-owned investment holding vehicles managed by eligible single-family offices in Hong Kong and (b) family-owned special purpose entities. The Bill is currently subject to scrutiny by the Legislative Council.
Tax incentives are also available to certain specified areas subject to qualifying conditions, such as interest on and any profit made in respect of Renminbi sovereign bonds, capital expenditure on specified environmental protection facilities, capital expenditure on plant and machinery specifically related to manufacturing, expenditure on computer hardware and software, and expenditure incurred on certain research and development activities.