"Substance" is needed for application of Hong Kong tax resident certificate
A set of new forms for applying a Hong Kong tax resident certificate ("HKTRC") under a comprehensive double tax agreement / arrangement ("CDTA") for corporation has recently been issued by the Inland Revenue Department. The new forms should be used for HKTRC applications starting from 1 February 2015. This News Flash discusses the major changes made to the application forms and shares our observations on the implications of these changes to treaty benefit claimants under CDTAs of Hong Kong.
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