Hong Kong Tax Analysis

Latest Tax Analysis

Court of Final Appeal affirms UK limited liability partnership not entitled to intra-group stamp duty relief

H121/2025 – 23 June 2025

On 16 June 2025, the Court of Final Appeal (CFA) handed down its judgment in John Wiley & Sons UK2 LLP and Wiley International LLC v. The Collector of Stamp Revenue [2025 HKCFA 11], dismissing the duty payers' appeal. The CFA upheld the Court of Appeal's (CA) decision, affirming that a UK limited liability partnership (LLP) is not entitled to stamp duty relief under Section 45 of the Stamp Duty Ordinance (SDO) for an intra-group transfer of Hong Kong stock.

2025

H121/2025 – 23 June 2025

Court of Final Appeal affirms UK limited liability partnership not entitled to intra-group stamp duty relief
[English]

H120/2025 – 17 June 2025

Court of First Instance upholds Board of Review's decision on taxpayer's burden of proof
[English]

H119/2025 – 26 February 2025

2025-26 Hong Kong Budget: A balanced budget to tackle deficit and cultivate
sustainable economic growth
[English] [Simplified Chinese]

2024

H118/2024 – 30 October 2024

A recent Court of Appeal case ruling on the taxability of royalties and upfront payment
[English]

H117/2024 – 15 October 2024

Court of First Instance ruled management fees paid to a related interposed management service agent not deductible
[English]

H116/2024 – 19 July 2024

Court of Appeal denied intra-group stamp duty relief for limited liability partnerships
[English]

H115/2024 – 28 February 2024

2024-25 Budget Analysis: A pragmatic budget with a view to achieving fiscal sustainability
[English] [Simplified Chinese]

2023

H114/2023 – 18 October 2023

Hong Kong’s Family Office Regime Poised to Draw Asia’s Wealth
[English] [Simplified Chinese]

H113/2023 – 8 March 2023

How Global Minimum Tax implementation timelines could affect top-up tax liabilities
[English]

H112/2023 – 22 February 2023

2023-24 Budget Analysis: A sustainable, balanced budget to embark on a new journey for Hong Kong's post-pandemic economy
[English] [Simplified Chinese]

2022

H111/2022 – 17 November 2022
Court of Appeal upheld upfront lump sum spectrum utilisation fees as non-deductible
[English]

H110/2022 – 29 October 2022
Foreign-sourced income exemption (FSIE) regime
Draft legislation and guidelines released
[English] [Simplified Chinese]

H109/2022 – 15 August 2022
Court of Final Appeal affirmed directors not liable to additional tax for signing incorrect returns
[English]

H108/2022 – 5 August 2022
Court accepted limited liability partnership for intra-group stamp duty relief
[English]

H107/2022 – 31 May 2022
The Impact of Pillar 2 on Hong Kong's Real Estate Sector
[English]

H106/2022 – 10 May 2022
Court of First Instance ruled interposed Hong Kong trading business not taxable
[English]

H105/2022 – 23 February 2022
2022-23 Budget Analysis: A comprehensive and forward-looking budget set to lead Hong Kong towards economic recovery
[English] [Simplified Chinese]

2021

H104/2021 – 6 August 2021
Court of Appeal rules vesting of Hong Kong stock by operation of merger law not chargeable with stamp duty
[English] 

H103/2021 – 26 April 2021
Codification of the tax treatment of court-free amalgamations of companies
[English] 

H102/2021 – 23 March 2021
Return of the Withholding Tax Deduction - May the Relief be with you
[English] [Simplified Chinese]

H101/2021 – 24 February 2021
2021-22 Budget Analysis: Pragmatic budget amid Hong Kong's record fiscal deficit paves way for post-pandemic recovery
[English] [Simplified Chinese] 

2020

H100/2020 – 23 October 2020
Inland Revenue Department updates guidance on revenue recognition under HKFRS 15 and appropriation of stock under HKAS 2
[English]

H99/2020 – 19 October 2020
BEPS Pillar Two – Impact on Hong Kong
[English] [Simplified Chinese] 

H98/2020 – 23 September 2020
Court of First Instance ruled upfront lump sum spectrum utilisation fees non-deductible
[English]

H97/2020 – 28 August 2020
Inland Revenue Department updated guidance on taxation and deduction related to intellectual property
[English]

H96/2020 – 23 July 2020
Inland Revenue Department issues revised guidance on Hong Kong Advance Pricing Arrangements
[English] [Simplified Chinese] [Japanese]

H95/2020 – 22 July 2020
Inland Revenue Department issues guidance on unified tax exemption regime for funds
[English]

H94/2020 – 11 May 2020
IRD revises guidance on advance rulings
[English] [Simplified Chinese] 

H93/2020 – 1 April 2020
IRD issues updated guidance on taxation of e-commerce transactions and digital assets
[English] [Simplified Chinese] 

H92/2020 – 26 February 2020
2020-21 Budget Analysis: A compassionate but prudent budget in the context of Hong Kong's fiscal deficit
[English] [Simplified Chinese] 

2019

H91/2019 – 7 August 2019
IRD issues guidance on application of PE profit attribution rules
[English] 

H90/2019 – 30 July 2019
IRD issues new guidance on Hong Kong Transfer Pricing matters
[English] [Simplified Chinese] [Japanese]

H89/2019 – 22 July 20119
Court of Final Appeal lump sum receipt arising from redevelopment arrangement non-taxable
[English]

H88/2019 – 16 May 2019
IRD issued guidance on tax deduction for R&D expenditures
[English] [Simplified Chinese]

H87/2019 – 27 February 2019
2019/20 Budget Analysis
[English] [Simplified Chinese]

2018

H86/2018 – 3 October 2018
Overview of tax law changes under new BEPS law
[English] 

H85/2018 – 22 January 2018
IFRS 17: Tax issues in Asia Pacific
[English]

H84/2018 – 27 July 2018
Court of Appeal rules "Initial Payment" arising from redevelopment arrangement taxable
[English] 

H83/2018 – 13 July 2018
Hong Kong passes BEPS and Transfer Pricing laws
[English] [Simplified Chinese] [Japanese]

H82/2018 – 4 May 2018
Enhanced deduction for R&D expenditures introduced
[English] [Simplified Chinese]

H81/2018 – 18 April 2018
Proposed expansion of deduction for purchase of intellectual property rights
[English] [Simplified Chinese]

H80/2018 – 28 February 2018
2018/19 Budget analysis
A holistic budget with forward-looking vision
[English] [Simplified Chinese]

H79/2018 – 27 February 2018
Employer-employee relationship
[English] [Simplified Chinese]

H78/2018 – 6 February 2018
Permanent Establishments
[English]

H77/2018 – 8 January 2018
Hong Kong to introduce statutory transfer pricing regime
[English] [Simplified Chinese] [Japanese]

H76/2018 – 5 January 2018
Two-tiered profits tax rates regime introduced in Hong Kong
[English] [Simplified Chinese]

2017

H75/2017 – 1 August 2017
Hong Kong signs multilateral instrument to modify bilateral tax agreements
[English] [Simplified Chinese]

H74/2017 – 28 March 2017
Oops!…They did it again
Hong Kong's aircraft leasing bill
[English] [Simplified Chinese]

H73/2017 – 22 February 2017
2017/18 Budget Analysis
Comprehensive, but cautious budget with commitment to review long-term tax policy
[English] [Simplified Chinese]

H72/2016 – 16 January 2017
Financial Institutions: Practice versus Law and Foreign Tax Credits?
[English] [Simplified Chinese]

2016

H71/2016 – 16 December 2016
Hong Kong Consultation on measures against BEPS
[English] [Simplified Chinese] [Japanese]

H70/2016 – 6 April 2016
Impact of BEPS Action 6 on source-based tax jurisdictions: the case of Hong Kong
[English] [Simplified Chinese]

H69/2016 – 16 March 2016
Potential impact of proposed Regulatory Capital Securities tax legislation to Hong Kong financial institutions
[English] [Simplified Chinese]

H68/2016 – 24 February 2016
2016/17 Budget Analysis - Commitment to long-term growth, but lack of exciting relief measures
[English] [Simplified Chinese]

H67/2016 – 20 January 2016
IRD partially clarifies tax treatment of court-free amalgamations
[English] [Simplified Chinese]

2015

H66/2015 – 11 December 2015
Hong Kong aims to sharpen its competitive edge with new corporate treasury centre tax regime
[English] [Simplified Chinese]

H65/2015 – 18 November 2015
Hong Kong profits tax exemption for private equity funds: Now a reality
[English] [Simplified Chinese]

H64/2015 – 22 July 2015
A Hong Kong perspective on the EU efforts to prevent harmful tax competition
[English] [Simplified Chinese]

H63/2015 – 12 May 2015
Update on proposed Hong Kong profits tax exemption for private equity funds
[English] [Simplified Chinese] 

H62/2015 – 21 April 2015
New protocol for Hong Kong-China double taxation arrangement signed
[English] [Simplified Chinese]

H61/2015 – 25 February 2015
2015/16 Budget Analysis: Comprehensive budget with diverse initiatives but housing measures are fewer than expected
[English] [Simplified Chinese] [Traditional Chinese]

H60/2015 – 13 January 2015
Hong Kong courts rule lump sum received on termination of contract not taxable
[English] [Simplified Chinese] 

2014

H59/2014 – 6 August 2014
Hong Kong signs first tax information exchange agreement
[English] [Simplified Chinese]

H58/2014 – 16 June 2014
Proposal to extend Hong Kong’s offshore fund exemption to private equity: A step in the right direction
[English] [Simplified Chinese]

H57/2014 – 25 March 2014
Hong Kong’s new Companies Ordinance creates opportunities for tax-free amalgamations
[English] [Simplified Chinese] [Japanese]

H56/2014 - 17 March 2014
Newly published advance ruling takes a hard line in determining the locality of profits
[English] [Simplified Chinese] [Japanese]

H55/2014 - 26 February 2014
2014/15 Hong Kong Budget Analysis: Visionary budget, cutting down "sweeteners" and few tax measures for individuals
[English] [Simplified Chinese] [Japanese]

H54/2014 - 26 February 2014
2014/2015 Hong Kong SAR Budget Highlights - Summary of allowances, deductions & tax rates
[English] [Simplified Chinese] [Japanese]

2013

H53/2013 - 20 December 2013
Update on Inland Revenue Department's views on tax treatment of share-based payment transactions: Opportunities and uncertainties
[English] [Simplified Chinese] [Japanese]

H52/2013 - 22 November 2013
Hong Kong CFA holds unrealized gains not chargeable to profits tax
[English] [Simplified Chinese] [Japanese]

H51/2013 - 22 August 2013
Development of Islamic finance in Hong Kong
[English] [Simplified Chinese]

H50/2013 – 27 February 2013
2013/14 Budget Analysis: Compassionate, pragmatic and cautious with clear positioning of Hong Kong
[English] [Simplified Chinese] [Japanese]

H49/2013 – 4 January 2013
Hong Kong court disallows deduction for manufacturing assets used in China
[English] [Simplified Chinese] [Japanese]