The Hong Kong Inland Revenue Department has published Advance Ruling Case No. 75, which was originally issued on 30 September 2024 and concerns the tax treatment of an in-kind dividend as part of a restructuring.
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Advance Ruling Case No. 75
1. The provisions of the Ordinance
The ruling applies in respect of sections 15H and 15I of the Inland Revenue Ordinance ("IRO").
2. Background
(a) The Applicant is a limited company incorporated in Hong Kong. Its principal activities are trad…