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Hong Kong Clarifies Tax Consequences Following Amalgamation

26 August 2016

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Approved Changes

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Hong Kong

On 18 August 2016, the Hong Kong Inland Revenue Department published an advance ruling dated 27 June 2016 concerning the tax consequences following an amalgamation of companies incorporated in Hong Kong. The ruling involves two companies belonging to the same group: Company A, the group's regional holding company; and Company B, a services company wholly owned by Company A The group is planning to vertically amalgamate Company B into Company A in 2016. According the ruling: Once amalgamated, Company A will succeed to all assets, property or liabilities of Company B, and any provision or accruals of Company B will...