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Hong Kong conducts compulsory spontaneous exchange of information for certain tax rulings

14 May 2020

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Tax Alerts, Legislation & Policy, Na...

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Hong Kong

Hong Kong’s Inland Revenue Department (IRD) recently issued a revised practice note (Revised DIPN 31) which explains that the IRD is now required to spontaneously furnish to the tax authorities of certain foreign jurisdictions any of the following four categories of tax rulings issued by the IRD:(i) Rulings related to preferential tax regimes1(ii) Unilateral Advance Pricing Arrangements and any other cross-border unilateral rulings in respect of transfer pricing(iii) Permanent establishment (PE) rulings(iv) Related party conduit rulingsIRD rulings on offshore claims in Hong Kong are not in-scope rulingsRevised DIPN 31 indicates that tax rulings in respect of Hong Kong offshore claims...