Hong Kong’s Commissioner of Inland Revenue (CIR) announced during a public seminar in February 2012 that the Inland Revenue Department (IRD) is preparing to launch an advance pricing arrangement (APA) programme starting in April 2012. Philip Wong and Petrina Chang of Deloitte in Hong Kong provide a break-down of the new facility.
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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
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