The Hong Kong Inland Revenue Department published an advance ruling on 8 December 2021 concerning the tax treatment of a capital reserve that was recognized as a result of the waiver of amounts due for financing.
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Advance Ruling Case No. 67
1. The provisions of the Ordinance
This ruling applies in respect of sections 14(1), 15(1)(c), 15(2), 61 and 61A of the Inland Revenue Ordinance ("IRO").
2. Background
(a) The Applicant is a wholly owned subsidiary of Company A, which belongs …