officers ie those who choose to retire voluntarily on the relinquishment of sovereignty in 1997 and those who decide to continue in Hong Kong employment post- 1997 until normal retirement?
I need an answer to these questions because taxation law has moved on somewhat since previous schemes of this nature were in operation. Whilst it is true that Section 188 Income and Corporation Taxes Act gives a tax exemption for these payments, that exemption operates only in respect of the charge under Section 148 of the Act. As Sections 148 and 188 operate only in respect of payments "not otherwise chargeable to tax" it is necessary for me to consider other taxing provisions (particularly Sections 19 and 596A of the Act) to determine whether these are relevant to the situation. I can assure that, once I have the necessary background from yourself and Alan McDonald I will immediately complete my deliberations and let you have my views.
Yours sincerely
Peter Bowen
P M BOWEN
-2-
CM/73CY