The Hong Kong Inland Revenue Department has published Advance Ruling Case No. 71, which was originally issued on 20 March 2023 and concerns the tax implications of a company's acquisition of an interest in a portfolio of project and infrastructure loan obligations. --- Advance Ruling Case No. 71 1. The provisions of the Ordinance This ruling applies in respect of sections 14, 16(1), 16(1)(d), 16(2)(c), 16(2)(f)(i) and 18K(3) of the Inland Revenue Ordinance ("IRO"). 2. Background (a) The applicant, Company A, was incorporated in Hong Kong. It is a special purpose vehicle held by its sole shareholder, Company C, on...