It is talking about Hong Kong Tax, Special Business, Calculating Profit tax of financial insituition. Can you please explain the relationship between S.14, S.15 (i), D7/84 and the interpretation on S.15(1)(i) below and provide a simple exmaple to explain the relationship. D7/84 ◦ The sequence in determining the taxability of interest income of an FI: Consider s.14(1) first If not chargeable under s.14(1), then consider s.15(1)(i) ◦ Interpretation on s.15(1)(i): (a) if the place where the funds are made available is a factor in determining source under s.14; and (b) if under s.14 it is decided that the interest is not subject to Hong Kong tax Then the matter must be viewed again under s.15(1)(i) but this time the place where the funds were provided is to be disregarded as a factor in determining the source of the interest
It is talking about Hong Kong Tax, Special Business, Calculating Profit tax of financial insituition.
Can you please explain the relationship between S.14, S.15 (i), D7/84 and the interpretation on S.15(1)(i) below and provide a simple exmaple to explain the relationship.
D7/84
◦ The sequence in determining the taxability of interest income of an FI:
Consider s.14(1) first
If not chargeable under s.14(1), then consider s.15(1)(i)
◦ Interpretation on s.15(1)(i):
(a) if the place where the funds are made available is a factor in
determining source under s.14; and
(b) if under s.14 it is decided that the interest is not subject to Hong Kong tax
Then the matter must be viewed again under s.15(1)(i) but this time the place where the funds were provided is to be disregarded as a factor in determining the source of the interest
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