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Unit_8_Partnership_and_other_cases

Charterhirebetweenaerodromesorairportswithinhkand

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Unformatted text preview: Unit 8 ­ Shipping Company Unit Non­resident ship­owner is granted exemption on its shipping income provided that it is exempted in its home country on same nature. The exempted sums include Carriage of goods/passengers in HK waters Towage operation proceeding to sea from HK waters Unit 8 ­ Aircraft Company Unit Resident owners of Aircraft [s.23C] Business managed or controlled in HK [s.23C(1)(a)] Business incorporated in HK [s.23C(1) (b)] Similar to resident owners of ships Unit 8 ­ Aircraft Company Unit Assessable Profits of HK aircraft owners [s.23C(2)] = Total aircraft profits x Relevant sums / Total aircraft income Relevant sums are receipts from 1. Carriage of passengers & goods (excluding those in transit) but including sums from a charter party (by demise or not) for outward flight from or commencing in HK From a flight charter not by demise for outward flight From a time charter not by demise – pro­rata basis on flying hours 2. Charter hire between aerodromes or airports within HK; and between HK and Macau (50% only in latter case) 3. Charter hire by demise (excluding those in point 2 & those attributable to permanent establishment outside HK) Unit 8 ­ Aircraft Company Unit Relevant Sums of HK aircraft owners [s.23C(2)] exclude Carriage of goods in transit Carriage of passengers in transit [Goods and passengers whose destination or place of departure is not HK] Unit 8 ­ Aircraft Company Unit Non­resident aircraft owners [s.23D] Casual landing, no liability [s.23D(5)] Assessable Profit = Fair percentage on relevant sums [s.23D(3)]. Election to re­compute on standard proportion method within 2 years Assessable Profit [same as ship owners in s.23C] proportion to world profits (except charter hire income) In s.23D, it should be concluded through a permanent establishment (i.e. an agent) in HK. Unit 8 ­ Aircraft Company Unit Double tax relief under an arrangement territory s.23C(2A) for resident aircraft owner If exempted by an arrangement territory, relevant sums should include those income exempted from arrangement territory Unit 8 – Financial Institutions Unit Financial Institutions – def...
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