Hong Kong is an important financial, trading and service hub for China and Asia which is a result of very good infrastructure, highly effective financial markets and a highly competitive tax regime. Hong Kong has always aimed at minimising administrative burdens which results in a very simple and easy-to-handle tax regime that many countries would wish for. Thus, more complicated tax regulations including tax treaties or anti-avoidance regulations including transfer pricing have been kept to a bare minimum, if included at all.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap