TNAG-1653-FCO40-2301-Proposed-extension-of-double-taxation-conventions-to-Hong-Ko-1987 — Page 2

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