Hong Kong’s Court of Final Appeal (CFA) ruled that year-end unrealized revaluation gains on listed securities held for sale were not taxable in Hong Kong. In a case called Nice Cheer Investment Limited (NCIL), the CFA rejected the CIR’s (Commissioner of Inland Revenue) reliance on the Spanish Prospecting case as supporting the CIR’s argument that unrealized profits were nonetheless taxable profits under the Inland Revenue Ordinance (IRO). The CIR had based its argument what it called two cardinal principles, i.e. for income tax purposes: (i) the word “profits” connotes actual or realized and not potential or anticipated profits; and (ii) neither profits nor losses may be anticipated.
Portugal: Azores raises VAT
»
Related Posts

Hong Kong cuts tax reserve certificate interest rates
Hong Kong’s Inland Revenue Department announced, on 28 January 2025, that starting from 3 February 2025 the new annual rate of interest payable on Tax Reserve Certificates will be 0.3417% against the current rate of 0.4250%, i.e. the new rate will
Read More
Hong Kong, Kyrgyzstan conclude tax treaty talks
Kyrgyzstan's Ministry of Economy and Commerce announced that it has concluded negotiations for an income tax treaty with Hong Kong on 17 January 2025. The treaty aims to eliminate double taxation of income and prevent tax evasion between the two
Read More
Hong Kong extends filing 2023/24 lodgement tax returns for year-end dates between January and March 2024 accounting year
The Hong Kong Inland Revenue Department (IRD) has released a Circular Letter to Tax Representatives on the Block Extension Scheme for Lodgement of 2023/24 Tax Returns on 15 January 2025. According to the letter, recognising the genuine
Read More
Hong Kong gazettes amendment to Minimum Tax for Multinational Enterprise Groups Bill 2024
Hong Kong announced that the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was published in the Gazette on 27 December. The Bill seeks to implement the international tax reform framework, Base Erosion and
Read More
Hong Kong publishes draft guidance on proposed company re-domiciliation regime
The Hong Kong Inland Revenue Department has released draft guidance on the proposed company re-domiciliation regime introduced under the Companies (Amendment) (No. 2) Bill 2024 on 20 December 2024. It is pending approval in the Legislative
Read More
Hong Kong, Croatia tax treaty enters into force
The income tax agreement between Hong Kong and Croatia entered into force on 20 December 2024. Hong Kong and Croatia signed an income and capital tax agreement on 24 January 2024, seeking to eliminate double taxation on income and capital while
Read More