On 30 December 2015, the Hong Kong Inland Revenue Department published guidance on the treatment of court-free company amalgamations. The guidance is as follows.
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Court-free Company Amalgamations
1. Profits tax consequences of a court-free amalgamation under the Companies Ordinance (Cap. 622) may not be the same as those in specific private merger ordinances in Hong Kong or in universal succession cases under foreign laws, which are not carried out for the purpose of obtaining tax bene…