CODE 18-78
CONF
Mr Paul
You will see
attached letter
Inland Revenue
confusion!
are
getting at.
COVERING SPURET HKC 106/1
Reference......
Double Taxation CAST (7
PAPER
구
from Mr Hum's minute on the
that he was not
what either the Inland Revenue
8
very
clear
the HK
1
share his
are
as
2. It seems to
follows:
me
:)
that the key points, nametheless,
HK have not in the
past concluded the policy of taking
DTAS, given at soure, lie all HK is taxed)
in came
any
is come
generated in
(i) HK are now
planning
some changes to their
policy
to
and lawt to grant exemption
person
Com
the
in
portion of a immed
eamed outside HK if it
proves
to the Inland Revenue that income tax was
pard
on that income in
where the semites
were rendered. (see
extract from the ID implementation checklist).
foreign counting
system, HK will greements with
iii) it seems to me that given the
independence of the tax want its ower, separate
other MK I
PRC. Or that
Or that basis
inchi they ME/PRC ITA
in
want to be included in
iv) I know from my
3.Ht
Aime in HK that there been informal contacts
have already been
between the and PRC ficials
subject. (See
3. It seems
seems
also the
la c
this
attached checklist). to me that the way forward world