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Offshore dividends used to reinvest in a subsidiary not regarded as discharging debt of a business carried on in Hong Kong
The Inland Revenue Department has recently published an advance ruling case no. 72 concerning whether offshore dividends were “received in Hong Kong” and whether the participation exemption would in any case exempt the offshore dividends, even if such dividends were regarded as “received in Hong Kong”.
This alert highlights our observations on the advance ruling case. Clients who are contemplating similar arrangements should contact their tax executive.