Preparing for a complex future

Page 3

Foreword Welcome to this collection of articles from the Hong Kong Institute of Certified Public Accountants’ monthly magazine A Plus in 2020, contributed by or featuring members of the Institute’s Taxation Faculty. The theme of the yearbook, Preparing for a more taxing future, is demonstrated through the wide coverage in the articles, which also represent the diverse responsibilities of the Taxation Faculty. The Taxation Faculty brings together the tax activities and programmes run by the Institute. These are primarily the technical, advocacy and liaison work as well as member services such as seminars, networking events, and a regular e-newsletter. The Taxation Faculty helps raise the profile of the taxation profession in Hong Kong and provides a stronger voice for members working in this field. It also offers a platform for the further development of high-quality tax services under the Institute. The faculty also lends support to other Institute initiatives, such as the advanced diploma in specialist taxation. The Taxation Faculty welcomes both Institute members and non-members to join. More information about the faculty can be found here. 2020 was a year of disruption due to the COVID-19 pandemic. Most of the world was focused on the task of battling the pandemic, with the attention of governments, businesses and individuals understandably concentrated on the disease, and on impeding its spread and mitigating its impact as much as possible. Governments mobilized unprecedented resources to support their locked-down economies and acquire the equipment and supplies health systems needed and, more recently, the vaccines essential for their populations. Businesses faced disruption to operations and customer demand, and had to adapt to the challenging times. Individuals were locked down, working from home or facing unemployment, or even their own personal battles with the virus. The pandemic has transformed economies. Coming at a time of continuing digital transformation of the economy, the pandemic has hastened the usage of new technologies, giving an unexpected boost to their providers, and also increased the economic power of the multinational enterprises that control much of the digital economic activity. The question of how governments tax these enterprises, and how businesses structure their activities are growing in importance, especially with the need to eventually pay back all the extra government spending on fighting the pandemic. This is why the work of the Organization for Cooperation and Development/ G20 Inclusive Framework on Base Erosion and Profit Shifting 2.0 initiative on the tax challenges arising from digitalization is so important. The release of the two blueprints in October 2020 will likely have significant impacts on tax systems across the world, including Hong Kong, and will be a focus of the Taxation Faculty going forward. This yearbook includes a number of articles on the initiative. Many in the taxation specialization in Hong Kong work advising Mainland-based companies or on Mainland taxation. The yearbook also covers this topic, and how taxation is developing in China. We hope you enjoy these articles, and continue to read A Plus to keep up to date with the latest developments in in Hong Kong and cross-boundary taxation.

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Articles inside

Article contributors

29min
pages 73-92

November 2020 An overview of the OECD’s Base Erosion and Profit Shifting 2.0 Pillar Two blueprint

10min
pages 67-69

December 2020 Examining the new DIPN covering ship leasing and management tax concessions

11min
pages 70-72

November 2020 An overview of the OECD’s Base Erosion and Profit Shifting 2.0 Pillar One blueprint

11min
pages 64-66

October 2020 The interaction of the accounting standards with the tax laws

10min
pages 61-63

October 2020 Views exchanged during the 2020 annual meeting with the IRD

9min
pages 58-60

October 2020 Leadership Profile: Moving on up Curtis Ng, Regional Tax Partner-in-Charge, Northern Region, at KPMG China

11min
pages 52-57

September 2020 Upfront lump sum spectrum utilization fees held as capital in nature and not deductible

8min
pages 50-51

September 2020 Roundtable discussion: Rules are changing: Will Hong Kong stay competitive? Experts discuss tax strategies at the Institute’s virtual Annual Taxation Conference

14min
pages 44-49

August 2020 Hong Kong revises DIPN on APAs to help manage tax uncertainties

9min
pages 40-42

September 2020 Proposed tax concession for carried interest

4min
page 43

August 2020 IRD issues revised practice note explaining the tax treatment of financial instruments under HKFRS 9

9min
pages 38-39

July 2020 A new limited partnership fund regime for Hong Kong

3min
page 35

July 2020 A summary of the taxation of offshore indirect transfers toolkit

11min
pages 32-34

June 2020 Taxation of charities

8min
pages 30-31

June 2020 Roundtable discussion: Navigating China’s tax system Experts discuss China tax matters at the China Taxation Conference

15min
pages 24-29

April 2020 IRD issues guidance on cryptocurrency taxation

10min
pages 16-17

May 2020 Revised DIPN 39 raises controversies over an apparently inconsistent application of the source principles

10min
pages 21-23

March 2020 Paying taxes in China

9min
pages 13-15

April 2020 Massive U.S. tax relief act to combat economic fallout from COVID-19

3min
page 20

February 2020 Economic substance law – the British Virgin Islands

9min
pages 10-12

Foreword

2min
page 3

January 2020 Court of Final Appeal decision on employee payments

10min
pages 4-6
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