HK Tax Study HubCombined single-file edition
HKFRS / HKAS →

Welcome to the HK Tax Study Hub · 歡迎使用香港稅務學習平台

A quick guide to what the Hub does and how to use it · 平台功能及使用方法簡介

Study material only · 僅供學習參考。 This Hub is not professional tax advice. Check the current law and IRD guidance before relying on a figure or section reference. · 本平台並非專業稅務意見;依賴任何數字或條文前,請核對現行法例及稅務局指引。

Hong Kong Tax Study Hub

Consolidated internal reference for HK profits, property and salaries tax, stamp duty, and depreciation allowances — built for (1) tax computation and taxable/deductible analysis on Hong Kong incorporated companies' financial statements, and (2) team study with worked illustrations drawn from IRD's Departmental Interpretation & Practice Notes (DIPNs).

雙語參考資料,涵蓋香港利得稅、物業稅、薪俸稅、印花稅及折舊免稅額,供稅務計算分析及團隊溫習之用。本平台僅供學習參考,不能取代《稅務條例》(第112章)及稅務局現行指引。

Study material — not professional advice · 學習材料,非專業意見 Nothing here is tax advice, and reading it creates no adviser–client relationship. This is written to one finance team's internal working standard and published openly because the underlying material is public — not because it has been reviewed for anyone else's use. It contains mistakes and goes out of date as the law changes. Verify against the Inland Revenue Ordinance (Cap. 112), the Stamp Duty Ordinance (Cap. 117) and current IRD guidance before relying on any figure for a filing position.
本平台所載內容並非稅務意見,閱讀不構成顧問關係。內容按某財務團隊的內部工作標準撰寫,因所依據的資料屬公開而公開發布,並未經審核供他人使用;內容或有錯誤,亦會隨法例變動而過時。在依賴任何數字作報稅立場前,請核對《稅務條例》(第112章)、《印花稅條例》(第117章)及稅務局現行指引。
IRD What's New read on 6 October 2026 — items from 1 Jun to 30 Sep 2026 reviewed. The Stamp Duty (Amendment) (No. 3) Bill 2026 is carried as a bill, and two 2026 Policy Address measures as proposed — none of the three is law yet. · 稅務局最新消息已於 6 October 2026 覆核。
What has changed in this Hub 11 revised · 4 still missing · updated 2026-09-25

What has changed in this Hub, and what is still missing. Tax content is primary; this is a pointer to it.

Revised

  • Computation Formats 2026-09-24
    New page. Pro-forma layout for property, salaries and profits tax, the plant and machinery schedule and personal assessment, each with per-line notes and a worked example.
  • Tax Reconciliation 2026-09-24
    New page. The 'here is a wrong computation plus ten notes' question type, with two full illustrations whose reconciliations close exactly.
  • ACCA TX-HKG 2026-09-24
    New page. Syllabus mapped to the Hub, the June 2026 examiner findings, and a complete 100-mark mock paper: 15 MCQs plus four 10-mark and two 15-mark questions.
  • Profits Tax by Entity 2026-09-24
    New page. Sole proprietorship, partnership and corporation compared, with partnership allocation, corporate partners and the apportioned two-tier band.
  • Personal Assessment 2026-09-24
    New page. Previously one paragraph inside Salaries Tax. Eligibility, the 2018/19 separate election, time limits, the standard-rate cap and four illustrations.
  • IRD What's New 2026-09-24
    New page. All 38 IRD items from 1 Jun to 16 Sep 2026, each marked enacted, bill or proposed, each linked to the page it changed.
  • Late payment surcharge and recovery 2026-09-24
    IRD Administration gained s.71: the 5% surcharge, the further 10% on tax plus surcharge, the instalment acceleration trap, and Part 12 recovery.
  • R&D enhanced deduction 2026-09-24
    Profits Tax gained the Type A 100% / Type B 300%-then-200% mechanics. Previously a single table row with no rates, and the MCQ fewest candidates answered correctly in June 2026.
  • Year-on-year allowances 2026-09-24
    Every allowance line now dual-stated: YA 2026/27 for current work, YA 2025/26 for the December 2026 exam. A build-time guard fails the build on a figure from neither year.
  • Mobile and accessibility 2026-09-24
    Fixed horizontal overflow on 14 of 23 panels at phone width, added meta descriptions, and corrected heading-level jumps. Contrast passes WCAG AA in both themes.
  • HKFRS / HKAS Study Platform linked 2026-09-25
    Companion platform for financial reporting added to the index and topbar.

Still missing, and why

  • Syllabus F — CBE skills
    This is operating ACCA's exam software — the spreadsheet and word-processing response areas. It cannot be practised anywhere but ACCA's own CBE platform, which the ACCA page links to. A written walkthrough could be added, but it is no substitute for sitting the real interface.
  • Past paper integration
    ACCA past papers and model answers are free to download but carry '© ACCA — All rights reserved'. This site is public, so they are linked, never reproduced. The mock paper on the ACCA page is original work in the same format.
  • Module 9 Chapter 46 cross-check
    The textbook has its own Personal Assessment chapter. That page was built from IRD's guide before the book was found to be readable by page rendering, so it has not been checked against Ch.46.
  • HKICPA Module 9 licence terms
    The illustrations pages paraphrase Module 9 with attribution and independently recomputed figures. HKICPA's own terms for derived study notes have not been read, so this remains an assumption rather than a verified position.

Dated, per-item IRD changes live on the IRD What's New page. This notice covers changes to the Hub itself.

Start here · 由此開始

The three tools you open first — what IRD changed recently, then the searchable transaction and DIPN indexes.

Tax types · 各稅種

One page per head of charge, each stating the current law with its statutory references.

Returns · 報稅表

Mapping the computation onto the actual BIR forms.

Worked illustrations · 例題

Paraphrased DIPN and Module 9 examples, recomputed against current rates.

Related platforms · 相關平台

A separate site. Opens in a new tab.

No page matches that search. · 沒有符合的頁面。

Living page — re-check each month

IRD What's New

Everything published on the Inland Revenue Department's What's New page, read against this Study Hub and marked up for what it actually changes.

稅務局最新消息整理稅務局「最新消息」所載事項,標明哪些已成為法例、哪些仍屬草案或政策建議,以及本平台已據此更新的頁面。
Source window IRD What's New read on 6 October 2026, covering the items published between 1 June 2026 and 30 September 2026. Since the previous read on 24 September the only substantive item is the Stamp Duty (Amendment) (No. 3) Bill 2026 (29 Sep, §2 below); the other new entries were routine fraudulent-email alerts, which change no tax rule. Anything published after 30 September 2026 is not reflected anywhere in this Hub.

1. How to use this page

The Study Hub's tax pages state the law as it stands. This page is the audit trail behind them: what IRD announced, whether it is enacted or still proposed, and which page was edited as a result.

MarkerMeaning
EnactedIn force, or an ordinance already gazetted. Safe to apply, subject to its own commencement date.
Gazetted / billPublished or before LegCo but not yet law. Know it is coming; do not apply it.
ProposedPolicy announcement only, needs an amendment ordinance. Do not apply it to a live filing or transaction.
The trap this page exists to stop A Policy Address measure is not law on the day it is announced. Both 2026 Policy Address measures below are drafted into this Hub as proposed, alongside the enacted figure. Quote the enacted figure in any computation until the amendment ordinance is gazetted.

2. Changes already applied to this Hub

IRD dateItemStatusPage updated
29 Sep 2026Stamp Duty (Amendment) (No. 3) Bill 2026 — intra-group relief: association test 90% → 75%, widened to non-share-capital entitiesBillStamp Duty §6
16 Sep 2026Child allowance $140,000 → $160,000, 2nd and subsequent children born on/after 16 Sep 2026ProposedSalaries Tax §5
16 Sep 2026Stamp duty waiver capped at $20,000 for newborn familiesProposedStamp Duty §6
8 Jul 2026Stamp Duty (Amendment) (No. 2) Ordinance 2026 — RMB settlement, dual-counter stockEnactedStamp Duty §2
14 Jul 2026Block Extension Scheme — "D" code 2025/26 dates extendedEnactedIRD Administration §2
12 Jun 2026Funds / FIHV / carried interest preferential regimes Bill 2026BillProfits Tax §2
10 Jun 2026Shipping-related activities & physical commodity trading Bill 2026BillProfits Tax §2
9 Jun / 27 Jul 2026Corporate treasury centres — Action Plan and consultationConsultationProfits Tax §2
30 Jun 2026Qualifying debt instruments / sovereign bonds list refreshedEnactedProfits Tax §2
8 Jun 2026GIR XML schema and user guides (GloBE Information Return)EnactedProfits Tax §2
17 Jun 2026AEOI Amendment Ordinance 2026 — amended CRSEnactedIRD Administration §7A
1 / 22 Jun 2026Crypto-Asset Reporting Framework — bill and guidance pageBillIRD Administration §7A
8 Jun 2026Business Tax Portal — new Responsible Person capacitiesEnactedIRD Administration §2
4 Sep / 13 Jul / 12 Jun 2026CDTAs with Slovenia (60th), Nigeria, CyprusSignedIRD Administration §7
Jul–Sep 2026Fraudulent email alerts ×4 + eTAX app warningAdvisoryIRD Administration §7A

3. Salaries tax & individuals

2026 Policy Address — child allowance 16 September 2026 · proposed

Child allowance rises from HKD 140,000 to HKD 160,000 for a taxpayer's second and subsequent children born on or after 16 September 2026, claimable until age 25 on the usual conditions. The additional child allowance for the year of birth and the following year rises to HKD 160,000 on the same basis — so HKD 320,000 per qualifying child in each of those two years.

ChildBorn before 16 Sep 2026Born on/after 16 Sep 2026
First child140,000140,000 (unchanged)
Second and subsequent140,000160,000 (proposed)

Intended effect from YA 2026/27, but it requires an amendment ordinance. Two traps: the increase does not reach first-born children, and it is keyed to the child's date of birth, not the year of assessment — an existing second child born in 2024 stays at HKD 140,000 indefinitely. IRD source.

4. Stamp duty

2026 Policy Address — newborn-family concession 16 September 2026 · proposed

A family with a child born in Hong Kong on or after 16 September 2026, at least one parent being a Hong Kong permanent resident, would receive a stamp duty waiver capped at HKD 20,000 on a residential property bought in the window from one year before to two years after the birth. Effective on enactment of the amendment ordinance. It is a capped waiver, not a rate change — on any purchase where AVD exceeds HKD 20,000 the benefit is a flat HKD 20,000. IRD source.

Stamp Duty (Amendment) (No. 3) Bill 2026 — intra-group relief Announced 29 Sep 2026, gazetted 2 Oct 2026 · bill

Relaxes the s.45 associated bodies corporate relief on intra-group transfers in three ways: the association test drops from 90% to 75%; "association" may be established through direct or indirect beneficial interests or voting rights, not only issued share capital; and relief is extended to entities with no share capital to measure, such as limited liability partnerships and companies limited by guarantee. First reading is set for 14 October 2026, and the Bill proposes to apply retrospectively to instruments executed on or after 25 February 2026.

Not law yet. The Stamp Duty page continues to state the enacted 90% test as its primary figure, with the proposed 75% carried as a marked note. The retrospective date matters: if the Bill passes as drafted, instruments already executed since 25 February 2026 that failed the 90% test but meet 75% would become relievable — worth flagging on any live transaction, but not a basis for stamping today. Press release.

Stamp Duty (Amendment) (No. 2) Ordinance 2026 Passed 8 Jul 2026, gazetted 17 Jul 2026 · enacted

Stamp duty on a transfer of dual-counter stock traded at the RMB counter may be calculated and paid in Renminbi, letting an investor settle trade and duty in one currency at one counter. The 0.2% rate is unchanged. Commencement is on a day to be appointed by the Secretary for Financial Services and the Treasury, pending HKEX system readiness — so it is gazetted but not yet operative. Press release.

5. Profits tax & concession regimes

DateMeasureWhat changesStatus
12 Jun 2026 Funds / FIHV / carried interest Bill 2026 Wider "fund" definition; broader schedule of qualifying assets (supports private credit); 5% incidental-transaction cap removed; relaxed SPE and family-owned SPE conditions; enhanced carried interest regime. Adds a tax reporting mechanism plus economic substance requirements modelled on the FIHV regime — the cost side of the deal. Bill — first reading 24 Jun 2026
10 Jun 2026 Shipping & physical commodity trading Bill 2026 Elective 15% concessionary rate for shipping-related activities, elected annually — a BEPS 2.0-aware alternative to the 0%/8.25% concessions, since a 0% rate invites top-up tax elsewhere. New half-rate (8.25%) concession for physical commodity trading. Bill — gazetted 12 Jun 2026
9 Jun / 27 Jul 2026 CTC Action Plan + consultation Government action plan for corporate treasury centres, then a consultation on enhancing the CTC tax concession. Expect qualifying-activity and safe-harbour conditions for the 8.25% CTC rate to move. Consultation
12 Aug 2026 FSTB response — carried interest FSTB reply to media enquiries on the preferential regime for carried interest; read with the June bill above. Context
30 Jun 2026 QDI / sovereign bond list Refreshed list of debt instruments and sovereign bonds eligible for profits tax concession or exemption. The published list is the test — an older copy will be wrong. Current
8 Jun 2026 GIR XML schema & user guides Machine-readable filing format for the GloBE Information Return, for MNE groups in scope of the Pillar Two top-up tax (fiscal years beginning on/after 1 Jan 2025). Published

6. Administration, AEOI & CARF

Block Extension Scheme — 2025/26 "D" code returns Circular, 14 July 2026 · enacted
Accounting Date Code "D" (1–31 December 2025)Previous due dateExtended due date
Paper filing17 August 202631 August 2026
Electronic filing17 September 20262 October 2026

Granted to help businesses and practitioners adapt to new compliance requirements; representatives are still urged to file well ahead. Codes "N" and "M" were not changed by this circular. Circular Letter to Tax Representatives, signed by the Commissioner, 14 Jul 2026.

DateItemWhy it matters
17 Jun 2026AEOI Amendment Ordinance 2026 passedImplements the OECD's amended Common Reporting Standard — new/changed due diligence and reporting fields for reporting financial institutions.
1 Jun 2026CARF Bill introduced into LegCoCrypto-Asset Reporting Framework — brings crypto-asset service providers into the reporting net. A new population of reporting entities, not merely a new field.
22 Jun 2026IRD CARF guidance pageIRD's operative CARF landing page — watch it for due diligence guidance as the bill progresses.
8 Jun 2026Business Tax Portal — new Responsible Person capacitiesMore capacities in which an RP may register a business for the BTP. Check capacity before opening a client account; a wrong-capacity account must be redone.
29 Jun 2026Advisory Committee on Tax Policy — first meetingStanding forum now shaping medium-term HK tax policy. Worth tracking for early signals on future regimes.
9 Jul 2026Annual Report on Performance Pledge 2025-26IRD's published turnaround times — useful when setting client expectations on objections and refunds.
31 Aug 2026IRD responds to Ombudsman direct investigation reportAdministrative practice, no change to tax rules.
2 Jul 2026Tax Obligations of Taxpayers and EmployersRefreshed IRD leaflet — the plain-language statement of s.51/s.52 duties.
11 Jun 2026Tax obligations of property ownersCompanion leaflet for property tax; pairs with the Property Tax page.

7. Treaty network

SignedJurisdictionNote
4 Sep 2026SloveniaHong Kong's 60th comprehensive double taxation agreement.
13 Jul 2026NigeriaFirst CDTA with Nigeria.
12 Jun 2026CyprusFirst CDTA with Cyprus.
Signed ≠ in force A CDTA takes effect only after both sides complete ratification. Check the IRD CDTA list for the in-force date and the first year of assessment covered before claiming treaty relief or a s.50 credit.

8. Fraud alerts

IRD issued fraudulent-email alerts on 6 July (fake legal prosecution notices), 22 July (phishing for email passwords), 4 September (fake tax audit notices) and 15 September 2026 (fake compliance notices and suspicious links), and warned on 25 August 2026 against downloading the eTAX Mobile Application from any unofficial channel.

Rule of thumb for clients IRD does not ask for passwords, does not send payment links by email, and does not distribute eTAX Mobile outside the official app stores. Any "compliance notice" arriving by email with a link should be verified by phoning IRD directly, not by clicking.

9. Noted — no content change

Read and deliberately not acted on, so a later reviewer need not re-read them: the five "Full text of The Chief Executive's 2026 Policy Address" transcripts (16 Sep 2026, the underlying speech text for the two measures above); LCQ19 on regulating charitable organisations (8 Jul 2026); LCQ21 on e-commerce tax policy and LCQ16 on fertility measures (17 Jun 2026); and the 15 Jun 2026 notice that LegCo would consider the AEOI Bill. These are position statements and procedural notices, not changes to the charging provisions.

Refresh discipline Re-read IRD What's New monthly, and always before finalising a filing position. When you do, update the "read on" date in the banner at the top of this page and add a row to §2 — an undated freshness claim is worse than none.

10. Source Documents

  • IRD — What's New (index of all items)read 24 Sep 2026
  • IRD — 2026 Policy Address, Tax-related Policy Measures (on Individuals)16 Sep 2026
  • Circular Letter to Tax Representatives — Block Extension Scheme 2025/26 (bel26ea.pdf)14 Jul 2026
  • Government press releases — stamp duty, funds/FIHV/carried interest, shipping & commodity trading, CTC, AEOI, CARF, CDTAsJun–Sep 2026

Every figure and date on this page comes from the IRD pages linked inline. Where an item is a bill or a policy announcement, the Study Hub keeps the enacted position as its primary statement and carries the change as a marked "proposed"/"bill" note — verify against the gazetted ordinance before relying on any of it for a filing position.

Exam preparation — TX-HKG (Taxation, Hong Kong)

ACCA TX-HKG

Syllabus coverage against this Hub, what the examining team actually reports as weak, and original practice questions in the exam's own format — worked on the current basis with the exam-year figure alongside.

ACCA TX-HKG 考試考試大綱對應本平台頁面、考官報告所指的弱項,以及依考試格式原創的練習題(15 條 MCQ 及三條 Section B),以現行年度計算並並列考試年度數字。附已驗證的 ACCA 官方連結。
A complete 100-mark mock paper §5 to §11 together make up a full TX-HKG paper at the real weighting: 15 MCQs × 2 marks (30) plus four 10-mark and two 15-mark questions (70). Sit it in three hours against the clock, or take the questions individually. Answers follow each question — cover them first.
Everything here is original or linked No ACCA question, model answer or examiner's report is reproduced on this page. Their material is linked to ACCA's own site, where it is free to download. The practice questions below were written for this Hub. See §10.

1. Exam format

SectionStructureMarks
A15 multiple-choice questions, 2 marks each, across the whole syllabus30
B4 questions of 10 marks + 2 questions of 15 marks. All compulsory.70
TotalThree-hour computer-based exam, predominantly computational100
Section A is 30% of the paper and the cheapest marks in it The examining team note that a good Section A performance "greatly facilitates the task of obtaining an overall pass". Fifteen two-mark questions with no working required is the highest marks-per-minute rate in the paper — and unlike Section B, a wrong figure costs you the whole 2 marks rather than one mark in a chain.

2. Which year of assessment applies

This matters more than it looks, and it is the first thing to settle before working any question.

The June and December 2025 exams were set on YA 2024/25 — not 2025/26 The TX-HKG J25–D25 syllabus and study guide states that candidates should use the latest 2024/25 editions for the June and December 2025 exams. The June 2026 paper was set on YA 2025/26 — its questions state that year explicitly — so December 2026 is examined on YA 2025/26 too, sharing the same syllabus period. Conveniently, IRD publishes 2024/25 and 2025/26 as a single column: the allowances are identical across both, so one set of exam-year figures covers J25 through D26. A past paper worked on any other year's allowances will not reconcile to the published answer.

Everywhere on this Hub the current basis is YA 2026/27. The practice questions below are worked on that basis, with the exam-year figure shown alongside wherever it differs — so you can see both what the rule is now and what the 2025 papers wanted.

ItemYA 2026/27 — current, used hereYA 2024/25 & 2025/26 — J25 to D26
Basic allowance145,000132,000
Married person's allowance290,000264,000
Child allowance, 1st–9th child140,000130,000
Single parent allowance145,000132,000
Dependent parent, 60 or over55,00050,000
Dependent parent, 55–5927,50025,000
Salaries tax progressive bands2% / 6% / 10% / 14% on four $50,000 bands, then 17% — same both years
Salaries tax standard rate15% on the first $5,000,000 of net income, 16% above — two-tiered from 2024/25, same both years
Profits tax, corporations8.25% on the first $2,000,000, 16.5% above — same both years
Property tax15% on net assessable value — same both years

Only the allowances moved. Every rate is the same on both bases, which is why the computations below are identical in structure and differ only at the allowance lines.

3. Syllabus → Hub coverage

Every TX-HKG syllabus area mapped to the page that covers it, with the gaps stated rather than glossed over.

§Syllabus areaCovered byStatus
AThe Hong Kong tax system and its administration IRD Administration — returns, assessment, objections and appeals, provisional tax, penalties, AEOI/CARF Full
BSalaries tax liabilities Salaries Tax + Illustrations + format Full
CProfits tax liabilities Profits Tax + Illustrations + Depreciation & Allowances + format + BIR51 guide Full
DProperty tax liabilities Property Tax + Illustrations + format Full
EPersonal assessment Personal Assessment — eligibility, the 2018/19 separate election, time limits, the standard-rate cap, four illustrations Full
FEmployability and technology skills Not covered — this is about operating the CBE software, spreadsheet and word-processing response areas. Practise it in ACCA's own CBE practice platform, which is the only place it can be practised properly. Gap
Two things on this Hub that are beyond TX-HKG Stamp duty is not in the TX-HKG syllabus — it sits in ATX-HKG. Our Stamp Duty pages are useful for work and for ATX, but do not spend TX revision time on them.
Also excluded by the syllabus: general anti-avoidance under s.61 and s.61A, all specific anti-avoidance provisions, and service company rules including DIPN 24 and 25. Our profits tax pages mention some of these — they are not examinable in TX.

4. What the examining team reports as weak

Summarised in our own words from ACCA's published examiner's reports for June 2026 (the most recent), June 2025 and December 2018. Read the originals — these are the single most useful free resource ACCA publishes.

What two consecutive years tell you
June 2026June 2025
WeakestTax administration · profits tax expense treatment · personal assessment computationTax administration · depreciation allowances · partnerships
BestProperty tax · profits tax computationProperty tax · salaries tax · profits tax
Tax administration is weakest in both years, and in both the report blames the same thing: candidates find written questions harder than computational ones and under-prepare a topic that is "examined regularly". It is the most reliable source of cheap marks in the paper.

Two things moved. Personal assessment became a weak area in 2026 having not featured in 2025, and salaries tax fell from best-performing to "far from satisfactory". Do not assume last year's strong topics are safe.
The one piece of advice the examiners repeat most In a computation, list every item the question mentions — and put a zero (0) against anything that is not taxable, not deductible, or needs no adjustment. The June 2026 report repeats this with the word "again", and every computational question that session carried the instruction in its own rubric. Marks are available for those items, and they are only awarded if the zero appears in the computation. A separate list of non-adjusting items underneath does not get them.

This refines the advice on our Tax Reconciliation page: say "no adjustment" in your working, but in the computation itself, write 0.
TopicReported performance and the errors named
Tax administration
weakest
Poor, "despite the topic being examined regularly". Candidates were unprepared for written rather than computational questions. Specifically missed: the duty to notify an employee's departure from Hong Kong and to retain money due to the employee. Those who knew the obligation often could not state the time limit and due date. Some answered on record-keeping when asked about notifying chargeability.
Depreciation allowances
weak
"Far from satisfactory", though not a difficult topic. Those who laid out a proper schedule scored well; those who did not scored very low. Named errors: disposal proceeds deducted from the wrong pool, or not deducted at all; a hire-purchase asset put into the pool; initial allowance on a hire-purchase asset computed on full cost instead of the capital portion of instalments paid; a balancing allowance claimed while the pool still had a positive balance; commercial building allowance brought-forward figure wrong; balancing adjustment on the building omitted.
Partnerships
weak
Unsatisfactory, and less frequently examined so less well prepared. Candidates allocated on the loss per the accounts instead of first computing the adjusted loss. Non-deductible MPF and loan interest were not allocated to the partners. Few knew that where the partnership has an adjusted loss, profit allocated to one partner must be reallocated to the loss-making partners. Loss relief for corporate partners was not understood. Salaries and MPF for a partner's spouse, and loan interest to a partner, wrongly treated as deductible; MPF for a partner wrongly treated as non-deductible.
Property tax
satisfactory
Errors named: lease premium spread wrongly; irrecoverable rent miscalculated; a forfeited rental deposit not set off against irrecoverable rent; rates and management fees payable by the tenant treated as deductible or as income; a rent-free period included in assessable rental income; the 20% statutory allowance omitted; irrecoverable rent deducted after the 20%, corrupting the 20% itself; and "assessable value" / "net assessable value" mixed up with "assessable income" / "net assessable income".

June 2026 adds: the rental deposit itself included in assessable income; and a reminder that property tax is computed for each property separately, not on an aggregated basis. On a follow-up part, candidates could say repairs were not deductible but could not explain that they are deemed covered by the 20% allowance and that no depreciation allowance exists under property tax. Covered here →
Salaries tax
best
Best performing. Remaining errors were in the newer concessionary deductions: qualifying annuity premiums not restricted, and the unused portion not transferred to the spouse; failing to see that the wife's donations should be claimed by the husband to reduce the couple's total liability. Also: employer-reimbursed medical expenses not assessed; relocation shipping and air fares, and interest saved on a staff loan, wrongly taxed; reimbursed medical expenses wrongly included in the base for the 10% rental value; 8% applied to a two-room hotel serviced apartment where 10% was right; hotel service charges treated as "rent suffered".

June 2026 — fell to "far from satisfactory". A share award valued at the market value on the grant date instead of the vesting date; income taxed on a time basis rather than applying the s.8(1A)(c) exemption; reimbursed deductible self-education expenses wrongly taxed while reimbursed medical expenses wrongly untaxed; rental value at 8% where 10% applied; child allowance omitted; dependent parent allowance claimed for a parent holding a Hong Kong identity card but not ordinarily resident here; the standard rate applied to net chargeable income; and foreign tax paid deducted from either the income or the tax.
Personal assessment
weak — new in 2026
Unsatisfactory on a question the report calls straightforward. Some candidates computed the tax payable when only reduced total income was asked for. Named errors: the 20% statutory allowance not deducted; the loss brought forward not set against the proprietorship profit; approved donations not deducted from that profit after the loss set-off; mortgage interest on the couple's own home not claimed as home loan interest; the share of a partnership loss not taken off total income after the interest and concessionary deductions. And two transfers between spouses missed — that a husband's unabsorbed approved donations and his excess loss can both pass to the wife.
Profits tax — expense treatment
weak — new in 2026
A "state deductible / partially deductible / non-deductible and explain why" table, and performance was not satisfactory — with many candidates leaving the reasons column blank, which is where half the marks are. Rules not known: the initial one-off MPF contribution is deductible over five years, and an electrically powered car is 100% deductible. Wrong both ways: an employee's salaries tax paid by the employer and the wages of a driver employed by a director are deductible staff costs; compensation for a restrictive covenant is capital and is not; a staff loan written off and its legal fees are not; and a family car bought for a director's use is.
Profits tax computation
good
Good overall. Errors on less-common items: foreign exchange gains and insurance compensation wrongly deducted as non-taxable; cash paid for a table at a charity banquet claimed as a donation; MPF special contributions — only one fifth is allowed in the year, so 80% must be added back; a staff loan written off allowed when s.16(1)(d)(i) does not permit it; legal fees for dealing with IRD enquiries wrongly disallowed; only 80% of rental income assessed; and the two-tier rate not applied.

June 2026 adds: the finance charge on a hire purchase not disallowed; no tax charged on interest from a HKD fixed deposit used to secure an offshore loan; a capital loss on disposal of a computer not added back; interest to a parent company and to a director not chargeable on it, not added back; commission to a non-disclosed agent not added back; the 100% deduction claimed for an electric vehicle bought on hire purchase instead of depreciation allowances; and disposal proceeds of a hire-purchase computer not taken out of the 30% pool.
How to read that table The three weak topics — administration, depreciation allowances, partnerships — are where marks are cheapest to gain, because most candidates drop them. The three practice questions below target the first two directly.

5. Practice — Section A

Fifteen questions, two marks each, on the current YA 2026/27 basis. Where a 2024/25 figure differs it is shown so you can see both. Answers and reasoning follow each question — cover them first.

Q1 · Salaries tax — source

Ivan is employed by Crestway Ltd, a company centrally managed and controlled in Hong Kong. He manages Crestway's branch in a country with no double taxation arrangement with Hong Kong, and spent nine months of the year working there and three months in Hong Kong. His salary is $100,000 a month. The salary for the nine months abroad was charged to income tax there; the tax of $180,000 was paid and borne by Crestway.

What is Ivan's assessable income for the year?

  1. $180,000
  2. $300,000
  3. $480,000
  4. $1,380,000
C — $480,000. Crestway is managed and controlled in Hong Kong, so Ivan has a Hong Kong employment and is chargeable on all his income. But s.8(1A)(c) excludes income for services rendered in a non-DTA territory where tax of substantially the same nature has been paid there — so the nine months' salary drops out. The foreign tax borne by the employer is itself a taxable perquisite. ($100,000 × 3) + $180,000 = $480,000. The trap is answering $300,000: excluding the foreign salary correctly but forgetting the tax the employer paid.
Q2 · Administration — penalty

Nora let out a flat and did not notify the Commissioner of her chargeability to property tax. She has no reasonable excuse. The property tax that would have been undercharged is $15,000.

What is the maximum penalty she faces under s.80(2)?

  1. $10,000
  2. $45,000
  3. $55,000
  4. $10,000 and imprisonment for six months
C — $55,000. Failure to notify chargeability under s.51(2) without reasonable excuse is an offence under s.80(2): a fine at level 3 ($10,000) plus treble the tax undercharged. ($15,000 × 3) + $10,000 = $55,000. Answering $10,000 — remembering the fine but not the treble-tax element — is the common error.
Q3 · Property tax

Raymond let a flat for the whole year at $25,000 a month. He paid rates of $9,000. The tenant paid management fees direct to the building's manager.

What is the property tax payable?

  1. $34,920
  2. $36,000
  3. $43,650
  4. $45,000
A — $34,920. Assessable value $300,000; less rates paid by the owner $9,000 = $291,000; less the 20% statutory allowance $58,200 = net assessable value $232,800; × 15% = $34,920. Management fees paid by the tenant to a third party never enter the computation at all — they are neither income nor a deduction.
Q4 · Property tax — premium

A premium of $240,000 is received on the grant of a four-year lease.

How much is included in assessable value each year?

  1. $60,000
  2. $80,000
  3. $240,000
  4. Nil — a premium is capital
B — $80,000. A premium is spread over the lease term but capped at 36 months (s.5B(4)). $240,000 × 12⁄36 = $80,000 a year for three years, not $60,000 over four.
Q5 · Profits tax — two-tiered rates

Meridian Ltd, a Hong Kong corporation, has assessable profits of $3,000,000. It is the only Hong Kong entity in its group.

What is the profits tax payable?

  1. $247,500
  2. $330,000
  3. $495,000
  4. $225,000
B — $330,000. ($2,000,000 × 8.25%) + ($1,000,000 × 16.5%) = $165,000 + $165,000. Answering $247,500 applies 8.25% to everything; $495,000 applies 16.5% to everything. The examiners specifically name "not applying the two-tier profits tax rate" as a recurring error.
Q6 · Depreciation allowances — hire purchase

A van with a cash price of $400,000 is acquired under hire purchase. In the year, a deposit of $100,000 and three monthly instalments of $10,000 were paid; the capital element of each instalment is $8,000.

What initial allowance is available?

  1. $240,000
  2. $78,000
  3. $74,400
  4. $60,000
C — $74,400. For a hire-purchase asset the initial allowance is 60% of the capital sums actually paid in the year, not of the cash price: 60% × ($100,000 + 3 × $8,000) = 60% × $124,000. Computing 60% × $400,000 = $240,000 is the error the examiners name explicitly. $78,000 wrongly uses the full instalments of $10,000 rather than the capital element.
Q7 · Profits tax — donations

Harbourline Ltd's profit after depreciation allowances is $800,000. It paid $320,000 to approved charitable institutions.

What deduction is allowed?

  1. $320,000
  2. $280,000
  3. $112,000
  4. Nil
B — $280,000. Capped at 35% of the profit after depreciation allowances: 35% × $800,000. The $40,000 excess lapses — it cannot be carried forward. Applying 35% to the donation itself gives $112,000, which is the wrong base.
Q8 · Salaries tax — rental value

Priya's income after allowable outgoings is $600,000. Her employer provides her with two rooms in a hotel.

What rental value is assessable?

  1. $24,000
  2. $48,000
  3. $60,000
  4. Nil
B — $48,000. 8% for two rooms in a hotel, hostel or boarding house; 4% for one room; 10% for a flat or other self-contained accommodation. 8% × $600,000. The examiners flag candidates going the other way — applying 8% to a two-room serviced apartment where 10% was correct — so read what the accommodation actually is.
Q9 · Personal assessment — eligibility

Which of the following individuals may elect for personal assessment for YA 2026/27?

  1. A 17-year-old whose parents are both alive
  2. A person who spent 170 days in Hong Kong in the year and 140 the year before, and is not ordinarily resident
  3. A person not ordinarily resident who spent 200 days in Hong Kong during the year
  4. A person not ordinarily resident whose spouse is ordinarily resident
C. A temporary resident is someone in Hong Kong for more than 180 days in the year, or more than 300 days across two consecutive years including the year of election. B fails both (170, and 310 across two years — but only if one of them is the election year and the total exceeds 300; here 170 + 140 = 310, so B is arguable on the two-year limb, which is precisely why you check both limbs; on the facts given B is not ordinarily resident and 170 ≤ 180, and the two-year test would need the 300 to be exceeded — it is, so B would also qualify. C is the unambiguous answer: 200 > 180 on the single-year test). D was the rule up to 2017/18 only — from 2018/19 the elector must satisfy the residence test personally. A fails the age test, which is only relaxed if both parents are dead.
Q10 · Personal assessment — time limit

By when must an election for personal assessment for YA 2026/27 be made?

  1. 31 March 2028
  2. 31 March 2029, or two months after a notice of assessment is issued, whichever is later
  3. Within six months of the assessment
  4. 31 March 2027
B. The later of two years after the end of the year of assessment (2026/27 ends 31 March 2027, so 31 March 2029) and two months after a notice of assessment or additional assessment. Six months is the withdrawal window, not the election window.
Q11 · Depreciation — commercial buildings

What is the annual allowance for a commercial building?

  1. 4% of the cost of construction
  2. 4% of the purchase price including land
  3. 20% of the residue of expenditure
  4. 10% of the cost of construction
A. 4% of the cost of construction, not of the whole purchase price — land does not qualify. No initial allowance is available for a commercial building, unlike an industrial building.
Q12 · Profits tax — bad debts

Which is deductible under s.16(1)(d)?

  1. An increase in the general provision for doubtful debts
  2. A specific trade debt written off as bad
  3. A loan to a member of staff written off
  4. All of the above
B. Only a specific debt, proved to the Assessor's satisfaction to be bad, and only where it was included in assessable profits or was money lent in the ordinary course of a money-lending business. A general provision is not deductible. A staff loan written off fails s.16(1)(d)(i) — the examiners name this exact item as a common error.
Q13 · Administration — objection

Within what period must a notice of objection be lodged?

  1. One month after the date of the notice of assessment
  2. Two months after the date of the notice of assessment
  3. One month after the end of the year of assessment
  4. Six years after the year of assessment
A. One month from the date of the notice of assessment, under s.64. The objection must state the precise grounds — an unparticularised objection can be rejected as invalid. Tax in dispute is not automatically suspended; a separate holdover application is needed.
Q14 · Profits tax — R&D enhanced deduction

Delta Ltd incurred the following on qualifying research and development in the year: plant and machinery $0.6m, a consultancy fee to an independent expert $0.4m, staffing costs of the research team $1.5m, and consumable items $0.9m.

What deduction may Delta Ltd claim under s.16B?

  1. $3.4m
  2. $7.2m
  3. $7.8m
  4. $8.2m
C — $7.8m. Split the spend first. Type B is staffing and consumables, $2.4m: the first $2m at 300% = $6.0m, the remaining $0.4m at 200% = $0.8m. Type A is plant and machinery plus the consultancy fee, $1.0m at 100%. Total $7.8m on $3.4m actually spent. The distractors are the three standard errors: $8.2m applies 300% to all of Type B, ignoring the $2m limit; $7.2m leaves the plant and machinery out as capital when s.16B allows it at 100%; $3.4m takes no enhancement at all. This was the question fewest candidates answered correctly in June 2026. Full treatment →
Q14b · Profits tax — MPF special contribution

Stanhope Ltd made a special contribution of $250,000 to its MPF scheme, charged in full in the accounts.

What adjustment is required in the profits tax computation?

  1. No adjustment
  2. Add back $250,000
  3. Add back $200,000
  4. Add back $50,000
C — add back $200,000. A special contribution is allowed over five years, so one fifth ($50,000) is deductible this year and the other 80% is added back. The examiners list this among the items candidates get wrong.
Q15 · Salaries tax — standard rate

Vivienne's net income, before personal allowances, is $6,000,000.

What is the standard-rate computation?

  1. $900,000
  2. $910,000
  3. $960,000
  4. $1,020,000
B — $910,000. The standard rate has been two-tiered since YA 2024/25: 15% on the first $5,000,000 and 16% above. ($5,000,000 × 15%) + ($1,000,000 × 16%). A flat 15% gives $900,000 and is the pre-2024/25 answer. Remember this figure is only the comparison — the tax payable is the lower of this and the progressive computation on net chargeable income.

6. Practice — Section B: tax administration 10 marks

The topic the examining team called the weakest in June 2025. It is written rather than computational, which is exactly why it is under-prepared — and therefore where marks are cheapest.

Question

Lantau Marine Limited prepares accounts to 31 March. The following events occurred during the year ended 31 March 2027:

  1. The company commenced a new business on 1 June 2026. It has not yet received a profits tax return for the year.
  2. It employed a new engineer, Mr Sandhu, on 1 September 2026.
  3. Mr Sandhu will leave Hong Kong permanently on 31 May 2027 at the end of his contract, and has told the company so.
  4. The company changed its registered office address on 1 January 2027.

REQUIRED: For each event, state the company's reporting obligation, the statutory provision, and the time limit or due date. (10 marks)

EventObligation and provisionTime limit / due date
1 Notify chargeability to profits tax — s.51(2). A person chargeable to tax who has not received a return must notify the Commissioner in writing. Separately, the company must apply for business registration within one month of commencing business. Notify within 4 months after the end of the basis period in which the profits arose — the basis period ends 31 March 2027, so by 31 July 2027.
Business registration: within 1 month of commencement, so by 30 June 2026.
2 Notify commencement of employment — s.52(4), Form IR56E. Required for any employee likely to be chargeable to salaries tax. Within 3 months of commencement, so by 30 November 2026.
3 Two separate obligations, and this is the one candidates miss.
(a) Notify the impending departure — s.52(6), Form IR56G.
(b) Withhold all money due to the employee — s.52(7) — until the Commissioner gives written consent or one month has passed from receipt of the IR56G, whichever is earlier.
(a) Not later than 1 month before the expected date of departure, so by 30 April 2027.
(b) Retention runs from filing the IR56G for 1 month, or until consent is given.
4 Notify change of address — s.51(8). Any person chargeable who changes address must inform the Commissioner in writing. Within 1 month of the change, so by 31 January 2027.
Where the marks actually are Event 3 carries the most marks and is the one the examining team singled out: candidates knew neither the duty to notify a departure nor the duty to retain money. Two marks are lost by giving only the notification. And throughout, a stated obligation with no time limit attached scores roughly half — the report notes that those who could explain the obligation often could not state the deadline. Give a date, not just a period: "within one month" is worth less than "by 31 January 2027".

7. Practice — Section B: depreciation allowances 10 marks

"Far from satisfactory" in June 2025. Every trap the examiners named is planted below.

Question

Reddane Engineering Limited prepares accounts to 31 March. Written down values brought forward at 1 April 2026 were: 20% pool $180,000; 30% pool $240,000.

During the year ended 31 March 2027:

  1. A lathe (20% pool) was bought for cash, $250,000.
  2. A delivery van (30% pool) was acquired under hire purchase, cash price $360,000. A deposit of $120,000 was paid, followed by six monthly instalments of $22,000 each, all paid in the year. The capital element of each instalment is $20,000.
  3. A computer from the 30% pool, originally costing $60,000, was sold for $18,000.

REQUIRED: Prepare the depreciation allowance schedule for YA 2026/27. (10 marks)

Reddane Engineering Limited — Depreciation Allowance Schedule · YA 2026/27
20%30%Allowances
Written down value b/f180,000240,000
Additions — lathe, cash250,000—
Additions — van, capital sums paid
$120,000 deposit + (6 × $20,000) = $240,000, not the $360,000 cash price
—240,000
Less: initial allowance, 60%(150,000)(144,000)294,000
280,000336,000
Less: disposal proceeds — computer, 30% pool
limited to original cost; $18,000 < $60,000 so the full proceeds come out
—(18,000)
Reduced value280,000318,000
Less: annual allowance(56,000)(95,400)151,400
Written down value c/f224,000222,600
Total depreciation allowances445,400
The trapWhy the wrong answer is wrong
IA on the van's full cash price60% × $360,000 = $216,000 instead of $144,000. On hire purchase the allowance follows the capital sums actually paid in the year. Named by the examiners as a specific error.
Van put in the pool at full costOnly the capital paid enters. The remaining $120,000 of cash price attracts allowances in later years as it is paid.
Disposal taken out of the 20% poolThe computer was in the 30% pool. Also named as a specific error.
Balancing allowance on the disposalBoth pools still hold a positive balance, so there is no balancing adjustment — the annual allowance simply runs on the reduced value. The examiners name claiming a balancing allowance on a positive pool.
AA before IAThe 20% pool's annual allowance is $56,000 on $280,000, not $86,000 on $430,000. Order is: additions → initial allowance → disposals → annual allowance.

Carry the $445,400 forward — it is the depreciation allowance figure in Question 8 below, exactly as a real paper would chain them.

8. Practice — Section B: profits tax computation 15 marks

Question

Reddane Engineering Limited (as above) reported a profit per the audited accounts of $4,000,000 for the year ended 31 March 2027. The following were charged or credited in arriving at it:

  1. Depreciation, $600,000. Depreciation allowances are as computed in Question 7.
  2. Cash donations to approved charitable institutions, $180,000.
  3. $50,000 paid for a table at a charity fundraising banquet.
  4. Interest of $90,000 on a loan from a director. The director is not chargeable to profits tax on it.
  5. A loan to a member of staff, $40,000, written off as irrecoverable.
  6. A special contribution to the company's MPF scheme, $250,000.
  7. Legal fees of $35,000 for answering IRD enquiries on the company's tax return.
  8. An exchange gain of $70,000 on trade receivables.
  9. Insurance compensation of $110,000 for trading stock destroyed by fire.
  10. Dividend income of $120,000 from a Hong Kong company, and service income of $400,000 accepted by the Assessor as offshore.

The company is the only Hong Kong entity in its group. REQUIRED: Compute the profits tax payable for YA 2026/27. (15 marks)

Reddane Engineering Limited — Profits Tax Computation · YA 2026/27
Profit per accounts4,000,000
Add: non-allowable items
Depreciation (1)600,000
Approved charitable donations, added back for relief below (2)180,000
Charity banquet table — consideration received, so not a donation (3)50,000
Interest to a director failing s.16(2) (4)90,000
Staff loan written off — fails s.16(1)(d)(i) (5)40,000
MPF special contribution, 80% (allowed over five years) (6)200,000
Legal fees re IRD enquiries — revenue, deductible (7)0
Exchange gain on trade receivables — revenue, taxable, already credited (8)0
Insurance compensation for trading stock — taxable, already credited (9)0
5,160,000
Less: non-assessable income
Dividend income — s.26 (10)(120,000)
Offshore service income (10)(400,000)
4,640,000
Less: depreciation allowances (Question 7)(445,400)
Profit before charitable donations (Y)4,194,600
Less: approved donations — lower of $180,000 and 35% × $4,194,600 = $1,468,110(180,000)
Assessable profit4,014,600
First $2,000,000 at 8.25%165,000
Remaining $2,014,600 at 16.5%332,409
Profits tax payable497,409
Note the three zeros Items 7, 8 and 9 need no adjustment — and each is written into the computation as 0. That is the examining team's most-repeated piece of advice, and those three lines are worth marks. Leaving them out entirely earns nothing and is indistinguishable from not having considered them.

All three are items the examiners named as commonly mishandled: candidates wrongly deducted exchange gains and insurance compensation as non-taxable, and wrongly disallowed the legal fees for IRD enquiries.

9. Practice — Section B: partnership assessment 10 marks

Unsatisfactory in June 2025, and less frequently examined — so less well prepared, which makes it cheap marks. Every error the examining team named is planted here.

Question

Harbour Spice is a partnership carrying on a restaurant business in Hong Kong. Amy and Ben share profits and losses 60 : 40. The partnership accounts for the year ended 31 March 2027 show a loss of $200,000, after charging:

  1. Salary to Amy, a partner — $360,000
  2. Salary to Amy's husband, employed as a chef — $240,000
  3. MPF contributions for Amy's husband — $12,000
  4. Amy's own mandatory MPF contributions as a self-employed person — $18,000
  5. Interest on a loan from Ben, a partner — $50,000
  6. Depreciation — $80,000
  7. Purchase of new kitchen utensils — $30,000
  8. Replacement of existing kitchen utensils — $25,000

Depreciation allowances for the year are $95,000.

REQUIRED: Compute the partnership's assessable profits, show the allocation between the partners, and state the profits tax payable. (10 marks)

Harbour Spice — Profits Tax Computation · YA 2026/27
Loss per the accounts(200,000)
Add: salary to Amy, a partner — s.17(2)360,000
Add: salary to a partner's spouse — s.17(2)240,000
Add: MPF for a partner's spouse — s.17(2)12,000
Add: interest on a loan from a partner — s.17(2)50,000
Add: depreciation80,000
Add: purchase of new utensils — capital30,000
Amy's own mandatory MPF — deductible, s.16AA0
Replacement of utensils — deductible, s.16(1)(f)0
572,000
Less: depreciation allowances(95,000)
Assessable profits477,000
Allocation between the partners
TotalAmyBen
Salary — Amy360,000360,000—
Salary and MPF — Amy's husband
disallowed under s.17(2), so attributed to Amy as the related partner
252,000252,000—
Interest — Ben50,000—50,000
Prior allocations662,000612,00050,000
Balance, shared 60 : 40(185,000)(111,000)(74,000)
Sub-total477,000501,000(24,000)
Reallocation of Ben's loss share
the partnership has assessable profits, so a partner cannot be left with a loss
—(24,000)24,000
Allocated assessable profits477,000477,000nil
Profits tax — unincorporated business, two-tiered: $477,000 × 7.5% (all within the first $2,000,000)35,775
The trapWhy
Allocating the loss per the accountsAllocation is of the adjusted figure. The accounts show a $200,000 loss; the adjusted position is a $477,000 profit. Named by the examiners as a specific error.
Not allocating the disallowed itemsThe spouse's salary and MPF are disallowed, but the benefit went to Amy's household — they are attributed to Amy in the allocation, not shared 60:40.
Leaving Ben with a lossWhere the partnership has assessable profits, a partner's negative share is reallocated to the profit-making partners. Ben pays nothing; Amy bears the whole $477,000. The mirror rule applies to a partnership loss.
Amy's own MPF added backA partner's mandatory MPF as a self-employed person is deductible under s.16AA. Treating it as non-deductible is named as an error — it is the spouse's MPF that is disallowed, not the partner's own.
Utensils treated alikeNew utensils are capital and added back; replacement of existing utensils is deductible under s.16(1)(f). The question gives both precisely to see whether you separate them.
Corporate rates usedA partnership is unincorporated: 7.5% / 15%, not 8.25% / 16.5%.

10. Practice — Section B: property tax, original and revised 10 marks

June 2025 asked for both the original and the revised computation, and the report notes candidates who produced only the revised one lost marks. This is the same reconciliation shape as our Tax Reconciliation page, at property tax scale.

Question

Mr Ho owns a shop in Hong Kong. He granted a three-year lease from 1 July 2026 at a monthly rent of $40,000, with a rent-free period for July and August 2026. A premium of $180,000 was received on 1 July 2026 and a rental deposit of $80,000 was taken.

The tenant stopped paying from January 2027. Rent for January to March 2027 was not recovered, and Mr Ho forfeited and retained the $80,000 deposit. Mr Ho paid rates of $16,000. The tenant paid management fees of $24,000 direct to the building manager.

His accountant produced the computation below. REQUIRED: Prepare both the original and the revised property tax computations for YA 2026/27, and reconcile them. (10 marks)

✗ As prepared by the accountant — YA 2026/27
Rent ($40,000 × 12)480,000
Premium180,000
Assessable value660,000
Less: rates(16,000)
Less: management fees(24,000)
620,000
Less: 20% statutory allowance(124,000)
Net assessable value496,000
Property tax at 15%74,400
✓ Revised — Mr Ho, Property Tax Computation, YA 2026/27
Rent accrued, September 2026 to March 2027 (7 × $40,000)
lease begins 1 July; July and August are rent-free, so no rent accrues for them
280,000
Premium, spread over 36 months: $180,000 × 9⁄36
9 months from 1 July 2026 to 31 March 2027
45,000
325,000
Less: irrecoverable rent
3 × $40,000 = $120,000, less the $80,000 deposit forfeited and retained
(40,000)
Assessable value285,000
Less: rates paid by the owner(16,000)
Management fees paid by the tenant to a third party0
269,000
Less: 20% statutory allowance ($269,000 × 20%)(53,800)
Net assessable value215,200
Property tax at 15%32,280
Reconciliation of net assessable value
Net assessable value per the original computation496,000
Rent for the pre-lease and rent-free months, wrongly included (5 × $40,000, net of 20%)(160,000)
Premium not spread over 36 months ($180,000 − $45,000, net of 20%)(108,000)
Irrecoverable rent, net of the forfeited deposit, not deducted ($40,000 net of 20%)(32,000)
Management fees paid by the tenant, wrongly deducted ($24,000 net of 20%)19,200
Revised net assessable value215,200
Four errors, and the tax is more than double $74,400 against $32,280. Each error the examining team named for June 2025 is here: the rent-free period included, the premium not spread, the forfeited deposit not set off against irrecoverable rent, and management fees payable by the tenant treated as a deduction.

Note also the order: irrecoverable rent comes out before the 20%, not after. Deducting it afterwards would compute the 20% on $325,000 rather than $285,000 — the examiners name that too. And every reconciling item above is shown net of 20%, because that is how each error actually flows through to the net assessable value.

11. Practice — Section B: salaries tax, husband and wife 15 marks

Question

Mr and Mrs Kwok are both employed in Hong Kong. For the year ended 31 March 2027:

Mr Kwok received a salary of $1,200,000 and a bonus of $150,000. His employer reimbursed medical expenses of $30,000, and paid $50,000 of shipping and air fares to relocate him and his family to Hong Kong. He is provided with a rent-free self-contained flat. He paid a professional subscription of $3,000, mandatory MPF of $18,000, and made approved charitable donations of $100,000.

Mrs Kwok received a salary of $280,000 and paid mandatory MPF of $14,000. She made no donations.

They have no children or dependants.

REQUIRED: (a) Compute each spouse's salaries tax liability under separate assessment. (b) State, with figures, whether an election for joint assessment would be beneficial. (c) Advise which spouse should claim the donations, and why. (15 marks)

(a) Mr Kwok — Salaries Tax Computation · YA 2026/27
Salary1,200,000
Bonus150,000
Medical expenses reimbursed by the employer — assessable30,000
Relocation shipping and air fares — not assessable0
1,380,000
Less: professional subscription — s.12(1)(a)(3,000)
Income after allowable outgoings1,377,000
Add: rental value, 10% (self-contained flat)137,700
Net assessable income before concessionary deductions1,514,700
Less: approved charitable donations
cap is 35% × $1,514,700 = $530,145, so the full $100,000 is allowed
(100,000)
Less: mandatory MPF contributions(18,000)
Net income1,396,700
Less: basic allowance D26 exam (YA 2025/26): $132,000(145,000)
Net chargeable income1,251,700
Progressive: 1,000 + 3,000 + 5,000 + 7,000 + ($1,051,700 × 17%)194,789
Standard rate: $1,396,700 × 15% (below the $5,000,000 threshold)209,505
Tax payable — the lower194,789
Mrs Kwok — Salaries Tax Computation · YA 2026/27
Salary280,000
Less: mandatory MPF contributions(14,000)
Net income266,000
Less: basic allowance(145,000)
Net chargeable income121,000
Progressive: 1,000 + 3,000 + ($21,000 × 10%)6,100
Standard rate: $266,000 × 15%39,900
Tax payable — the lower6,100
(b) Joint assessment comparison
Combined net income ($1,396,700 + $266,000)1,662,700
Less: married person's allowance D26 exam (YA 2025/26): $264,000(290,000)
Net chargeable income1,372,700
Progressive: 16,000 + ($1,172,700 × 17%)215,359
Standard rate: $1,662,700 × 15%249,405
Tax under joint assessment215,359
Total under separate assessment ($194,789 + $6,100)200,889
Joint assessment is worse by14,470

(b) conclusion. Joint assessment should not be elected. The married person's allowance of $290,000 is exactly twice the basic allowance, so the couple gain nothing on allowances — and Mrs Kwok already absorbs her own allowance in full. Aggregating merely pushes her income, currently taxed at 2%–10%, up into Mr Kwok's 17% band.

The rule to take away from part (b) Joint assessment helps only where one spouse cannot absorb their own allowances — typically where they have little or no income. Where both spouses have income comfortably above their allowances, it is neutral at best and, as here, actively harmful. Never assume it is beneficial: compute both.

(c) Who should claim the donations. Mr Kwok — as computed above. Two reasons, and the second is the one candidates miss:

  • The cap. Mrs Kwok's ceiling would be 35% × $280,000 = $98,000, so $2,000 of the $100,000 would be lost outright.
  • The marginal rate. Mr Kwok's top slice is taxed at 17%, Mrs Kwok's at 10%. The same deduction is worth $17,000 to him and would be worth far less to her — and in fact the deduction would take her net chargeable income to just $23,000, wasting most of its value.

Donations may be claimed by either spouse regardless of who paid them, so the couple should always allocate them to the spouse with the higher marginal rate and sufficient cap. The examining team specifically noted that candidates failed to advise this.

ACCA TX-HKG

Practice Question Bank

ACCA TX-HKG — Section A · 282 original multiple-choice questions across all five syllabus areas, every computational answer generated and checked against the Hub's own tax-computation engine so the arithmetic cannot drift from the explanation.

題庫 AACCA TX-HKG 題庫 Section A:282 條原創選擇題,涵蓋五個考試範疇,可按範疇、主題或難度篩選。選好答案後按核對即會顯示對錯並即時計分。所有涉及計算的題目及其錯誤選項均由本平台的稅務計算模組產生,確保數字與解釋一致,亦支援關鍵字搜尋及隨機抽15題練習。

What this is

A large, filterable bank of original Section A-style MCQs, built to mirror the ACCA TX-HKG syllabus weighting and the errors the examining team has actually reported — not a copy of any past paper or examiner's report question.

How the computational questions were built Every computational question's correct answer and its wrong-option distractors come from the same small Python tax-computation module (scripts/qbank_tax.py) that this Hub's other worked illustrations use. The distractors are not arbitrary wrong numbers — each one reproduces a specific error pattern the examining team has reported (forgetting the treble-tax element of a s.80(2) penalty, applying the standard rate to net chargeable income instead of net income before allowances, spreading a lease premium over the full term instead of the 36-month cap, and so on).

Coverage by syllabus area

AreaSyllabus areaQuestions
ATax system and administration44
BSalaries tax72
CProfits tax98
DProperty tax35
EPersonal assessment33
Total282

Spread over 110 distinct topics; 68 of the 282 questions are computational (the rest test a rule, a deadline or a distinction conceptually).

How to use it

  • Filter by syllabus area or difficulty, or type a keyword or section reference (e.g. s.16B, "premium", "two-tier") into the search box — the filters combine.
  • Random 15 pulls a fresh, shuffled set of 15 questions from whatever the current filters allow — close to a real Section A sitting's length and a reasonable practice pace of under two minutes each. It also resets the score and clears every answer, so each draw is a clean attempt.
  • Select an option, then click Show answer — it marks your choice Correct or Incorrect, then reveals the full explanation and section reference. 1 correct answer = 1 mark; the Score counter at the top right of the toolbar counts marks scored out of questions checked so far.
  • Show all clears the Random 15 selection and returns to the ordinary filtered view — it does not affect the score.

The question bank

Score: 0 / 0 Showing 282 of 282
A · Tax system and administration Statutory time limits Easy

Q001. Within what period must a taxpayer or employer notify chargeability to profits tax where no return has been issued?

A · Tax system and administration Statutory time limits Easy

Q002. Within what period must a taxpayer or employer notify the commencement of an employee's employment?

A · Tax system and administration Statutory time limits Easy

Q003. Within what period must a taxpayer or employer notify the cessation of an employee's employment?

A · Tax system and administration Statutory time limits Easy

Q004. Within what period must a taxpayer or employer notify that an employee is about to leave Hong Kong permanently?

A · Tax system and administration Statutory time limits Easy

Q005. Within what period must a taxpayer or employer notify a change of the taxpayer's postal address?

A · Tax system and administration Statutory time limits Easy

Q006. Within what period must a taxpayer or employer apply for business registration after commencing business?

A · Tax system and administration Statutory time limits Easy

Q007. Within what period must a taxpayer or employer lodge a valid notice of objection against an assessment?

A · Tax system and administration Statutory time limits Easy

Q008. Within what period must a taxpayer or employer appeal to the Board of Review against the Commissioner's determination?

A · Tax system and administration Records Easy

Q009. For how long must a person carrying on a trade, profession or business in Hong Kong retain sufficient business records?

A · Tax system and administration Records Medium

Q010. From what point does the statutory retention period for business records run?

A · Tax system and administration Records Medium

Q011. A landlord letting a Hong Kong property is obliged to keep rental records. What must those records cover?

A · Tax system and administration Additional assessment Medium

Q012. Within what period may the Assessor normally raise an additional assessment where income has been under-assessed?

A · Tax system and administration Additional assessment Medium

Q013. Where a taxpayer has been guilty of fraud or wilful evasion, within what period may an additional assessment be raised?

A · Tax system and administration Penalties Medium

Q014. A taxpayer failed to notify chargeability to tax under s.51(2) without reasonable excuse. The tax that would have been undercharged is $11,250. What is the maximum penalty on summary conviction?

A · Tax system and administration Penalties Medium

Q015. A taxpayer failed to notify chargeability to tax under s.51(2) without reasonable excuse. The tax that would have been undercharged is $24,000. What is the maximum penalty on summary conviction?

A · Tax system and administration Penalties Easy

Q016. A taxpayer failed to notify chargeability to tax under s.51(2) without reasonable excuse. The tax that would have been undercharged is $8,400. What is the maximum penalty on summary conviction?

A · Tax system and administration Penalties Hard

Q017. A taxpayer failed to notify chargeability to tax under s.51(2) without reasonable excuse. The tax that would have been undercharged is $46,500. What is the maximum penalty on summary conviction?

A · Tax system and administration Penalties Medium

Q018. What is the maximum additional tax the Commissioner may assess under s.82A for an incorrect return made without reasonable excuse?

A · Tax system and administration Penalties Hard

Q019. What is the maximum penalty for wilfully and with intent evading tax, on conviction on indictment?

A · Tax system and administration Late payment surcharge Hard

Q020. Tax of $100,000 remained unpaid more than six months after the due date. What is the total amount now payable, including surcharges?

A · Tax system and administration Late payment surcharge Hard

Q021. Tax of $48,000 remained unpaid more than six months after the due date. What is the total amount now payable, including surcharges?

A · Tax system and administration Late payment surcharge Hard

Q022. Tax of $250,000 remained unpaid more than six months after the due date. What is the total amount now payable, including surcharges?

A · Tax system and administration Late payment surcharge Hard

Q023. A demand note is payable in two instalments and the taxpayer misses the first. What is the consequence?

A · Tax system and administration Late payment surcharge Medium

Q024. A taxpayer in financial difficulty applies successfully to pay tax by instalments. What is the effect on surcharges?

A · Tax system and administration Recovery of tax Medium

Q025. Under which provision may the Commissioner issue a recovery notice to a third party who owes money to the defaulter?

A · Tax system and administration Recovery of tax Medium

Q026. Under which provision may the Commissioner apply to a District Judge to stop a defaulter leaving Hong Kong?

A · Tax system and administration Recovery of tax Medium

Q027. Under which provision may the Commissioner sue for tax in default as a civil debt in the District Court?

A · Tax system and administration Recovery of tax Medium

Q028. Four people own a let property as co-owners in equal shares. How are they liable for the property tax?

A · Tax system and administration Provisional tax Hard

Q029. By when must an application to hold over payment of provisional tax be made?

A · Tax system and administration Provisional tax Medium

Q030. Which of the following is a valid statutory ground for holding over provisional salaries tax?

A · Tax system and administration Assessment Medium

Q031. What may the Assessor issue where a taxpayer fails to file a return?

A · Tax system and administration Objections Medium

Q032. What happens to the tax in dispute while an objection is under consideration?

A · Tax system and administration Objections Medium

Q033. A notice of objection is lodged in time but states no grounds. What is the consequence?

A · Tax system and administration Sources of tax law Easy

Q034. What is the status of a DIPN?

A · Tax system and administration Sources of tax law Medium

Q035. Which sequence correctly ranks the authority of Hong Kong tax sources, highest first?

A · Tax system and administration Avoidance and evasion Easy

Q036. What distinguishes tax avoidance from tax evasion?

A · Tax system and administration Advance rulings Medium

Q037. What is the effect of a specific advance ruling issued by the Commissioner?

A · Tax system and administration Administration Easy

Q038. Who is empowered to assess and collect tax under the Inland Revenue Ordinance?

A · Tax system and administration Board of Review Easy

Q039. What is the Board of Review?

A · Tax system and administration Appeals Medium

Q040. On what basis may a Board of Review decision be appealed to the Court of First Instance by way of case stated?

A · Tax system and administration Block Extension Scheme Hard

Q041. For 2025/26 profits tax returns with Accounting Date Code 'D', what were the extended lodgement dates announced by the Commissioner on 14 July 2026?

A · Tax system and administration Returns and filing Medium

Q042. When is a newly incorporated Hong Kong company normally issued with its first profits tax return?

A · Tax system and administration Compliance Medium

Q043. Besides simply processing what a return states, what compliance activity does the Inland Revenue Department carry out?

A · Tax system and administration Filing Easy

Q044. What must generally accompany the first return filed by a newly registered taxpayer, in addition to the return itself?

B · Salaries tax Source of employment Easy

Q045. Under the totality of facts test in Goepfert, which three factors principally determine whether an employment is a Hong Kong employment?

B · Salaries tax 60-day rule Easy

Q046. Income from services rendered wholly outside Hong Kong by a non-Government employee is excluded from salaries tax unless the person visited Hong Kong for what period during the basis period?

B · Salaries tax 60-day rule Hard

Q047. An employee's ordinary visits to Hong Kong total 59 days. On two occasions he also departed very early in the morning on a connecting flight. How many days does he count as present?

B · Salaries tax s.8(1A)(c) exclusion Hard

Q048. An employee has a Hong Kong employment with a company managed and controlled in Hong Kong. He spent 9 months working in a territory with no double taxation arrangement with Hong Kong, and that salary bore local income tax of $180,000, which the employer paid on his behalf. His salary is $100,000 a month. What is his assessable income?

B · Salaries tax s.8(1A)(c) exclusion Hard

Q049. An employee has a Hong Kong employment with a company managed and controlled in Hong Kong. He spent 10 months working in a territory with no double taxation arrangement with Hong Kong, and that salary bore local income tax of $250,000, which the employer paid on his behalf. His salary is $120,000 a month. What is his assessable income?

B · Salaries tax s.8(1A)(c) exclusion Hard

Q050. An employee has a Hong Kong employment with a company managed and controlled in Hong Kong. He spent 8 months working in a territory with no double taxation arrangement with Hong Kong, and that salary bore local income tax of $150,000, which the employer paid on his behalf. His salary is $80,000 a month. What is his assessable income?

B · Salaries tax Directors' fees Medium

Q051. How are directors' fees from a company resident in Hong Kong treated?

B · Salaries tax Rental value Medium

Q052. An employee's income after allowable outgoings is $998,000. The employer provides a self-contained flat rent free, at a cost to the employer of $240,000 for the year. What rental value is assessable?

B · Salaries tax Rental value Medium

Q053. An employee's income after allowable outgoings is $600,000. The employer provides two rooms in a hotel rent free, at a cost to the employer of $156,000 for the year. What rental value is assessable?

B · Salaries tax Rental value Medium

Q054. An employee's income after allowable outgoings is $750,000. The employer provides a single hotel room rent free, at a cost to the employer of $132,000 for the year. What rental value is assessable?

B · Salaries tax Rental value Medium

Q055. An employee's income after allowable outgoings is $1,200,000. The employer provides a rent-free house rent free, at a cost to the employer of $420,000 for the year. What rental value is assessable?

B · Salaries tax Rent suffered Medium

Q056. An employee pays part of the rent on employer-provided quarters. How is the 'rent suffered' treated?

B · Salaries tax Rental value Hard

Q057. On what base is the 10% rental value calculated?

B · Salaries tax Fringe benefits Medium

Q058. How is the following treated for salaries tax purposes?
Medical expenses reimbursed by the employer

B · Salaries tax Fringe benefits Medium

Q059. How is the following treated for salaries tax purposes?
Shipping costs and air fares paid by the employer to relocate a new employee and family to Hong Kong

B · Salaries tax Fringe benefits Medium

Q060. How is the following treated for salaries tax purposes?
Interest saved on an interest-free loan from the employer

B · Salaries tax Fringe benefits Medium

Q061. How is the following treated for salaries tax purposes?
A holiday journey paid for by the employer

B · Salaries tax Fringe benefits Medium

Q062. How is the following treated for salaries tax purposes?
The employer settling the employee's personal credit card bill

B · Salaries tax Fringe benefits Medium

Q063. How is the following treated for salaries tax purposes?
A corporate club membership in the company's name, used by an employee

B · Salaries tax Fringe benefits Medium

Q064. How is the following treated for salaries tax purposes?
Reimbursement of an employee's deductible self-education expenses

B · Salaries tax Share awards Hard

Q065. On what value is a share award benefit assessed?

B · Salaries tax Share options Medium

Q066. A share option has a vesting period of 730 days, of which 292 were spent working in Hong Kong. What proportion of the gain on exercise is assessable to Hong Kong salaries tax?

B · Salaries tax Share options Medium

Q067. A share option has a vesting period of 1095 days, of which 365 were spent working in Hong Kong. What proportion of the gain on exercise is assessable to Hong Kong salaries tax?

B · Salaries tax Share options Medium

Q068. A share option has a vesting period of 365 days, of which 146 were spent working in Hong Kong. What proportion of the gain on exercise is assessable to Hong Kong salaries tax?

B · Salaries tax Termination payments Medium

Q069. How is a contractual gratuity payable on completion of a fixed-term contract treated?

B · Salaries tax Termination payments Medium

Q070. How is a statutory severance payment under the Employment Ordinance treated?

B · Salaries tax Concessionary deductions Easy

Q071. What is the maximum annual deduction for the following?
Self-education expenses

B · Salaries tax Concessionary deductions Easy

Q072. What is the maximum annual deduction for the following?
Mandatory MPF contributions by an employee

B · Salaries tax Concessionary deductions Easy

Q073. What is the maximum annual deduction for the following?
Elderly residential care expenses, per parent or grandparent

B · Salaries tax Concessionary deductions Easy

Q074. What is the maximum annual deduction for the following?
Home loan interest, without a qualifying child

B · Salaries tax Concessionary deductions Easy

Q075. What is the maximum annual deduction for the following?
Qualifying premiums under a VHIS certified plan, per insured person

B · Salaries tax Concessionary deductions Easy

Q076. What is the maximum annual deduction for the following?
Qualifying annuity premiums and MPF voluntary contributions combined

B · Salaries tax Concessionary deductions Easy

Q077. What is the maximum annual deduction for the following?
Domestic rents for a non-owner-occupier, without a qualifying child

B · Salaries tax Concessionary deductions Easy

Q078. What is the maximum annual deduction for the following?
Assisted reproductive services expenses

B · Salaries tax Charitable donations Medium

Q079. A taxpayer's income after other deductions is $1,514,700 and approved charitable donations of $100,000 were paid. What deduction is allowed?

B · Salaries tax Charitable donations Medium

Q080. A taxpayer's income after other deductions is $490,000 and approved charitable donations of $210,000 were paid. What deduction is allowed?

B · Salaries tax Charitable donations Medium

Q081. A taxpayer's income after other deductions is $800,000 and approved charitable donations of $350,000 were paid. What deduction is allowed?

B · Salaries tax Deductible outgoings Medium

Q082. What is the statutory test for deducting an employee's outgoings and expenses?

B · Salaries tax Deductible outgoings Easy

Q083. How is the cost of travelling between home and the workplace treated?

B · Salaries tax Personal allowances Easy

Q084. For the year of assessment 2025/26 - the basis examined in December 2026 - what is the basic allowance?

B · Salaries tax Personal allowances Easy

Q085. For the year of assessment 2025/26 - the basis examined in December 2026 - what is the married person's allowance?

B · Salaries tax Personal allowances Easy

Q086. For the year of assessment 2025/26 - the basis examined in December 2026 - what is the child allowance for each of the 1st to 9th child?

B · Salaries tax Personal allowances Easy

Q087. For the year of assessment 2025/26 - the basis examined in December 2026 - what is the dependent parent allowance for a parent aged 60 or above, not residing with the taxpayer?

B · Salaries tax Personal allowances Easy

Q088. For the year of assessment 2025/26 - the basis examined in December 2026 - what is the single parent allowance?

B · Salaries tax Personal allowances Medium

Q089. What is the relationship between the married person's allowance and the basic allowance?

B · Salaries tax Personal allowances Hard

Q090. A taxpayer's mother holds a Hong Kong identity card but lives permanently outside Hong Kong. Can the dependent parent allowance be claimed?

B · Salaries tax Personal allowances Medium

Q091. Two siblings each contribute to the maintenance of the same dependent parent. How is the dependent parent allowance given?

B · Salaries tax Personal allowances Hard

Q092. What is the relationship between the dependent parent allowance and the deduction for elderly residential care expenses?

B · Salaries tax Computation Hard

Q093. A taxpayer's net income before allowances is $1,396,700 and the allowances claimed total $145,000 (single, basic allowance only). What is the salaries tax payable, ignoring any one-off reduction?

B · Salaries tax Computation Hard

Q094. A taxpayer's net income before allowances is $266,000 and the allowances claimed total $145,000 (single, basic allowance only). What is the salaries tax payable, ignoring any one-off reduction?

B · Salaries tax Computation Hard

Q095. A taxpayer's net income before allowances is $1,049,800 and the allowances claimed total $145,000 (single, basic allowance only). What is the salaries tax payable, ignoring any one-off reduction?

B · Salaries tax Computation Hard

Q096. A taxpayer's net income before allowances is $600,000 and the allowances claimed total $290,000 (married, married person's allowance). What is the salaries tax payable, ignoring any one-off reduction?

B · Salaries tax Standard rate Medium

Q097. What is the salaries tax standard rate from the year of assessment 2024/25?

B · Salaries tax Progressive rates Easy

Q098. What are the progressive rates applied to net chargeable income?

B · Salaries tax Joint assessment Hard

Q099. When is an election for joint assessment under s.10(2) beneficial?

B · Salaries tax Charitable donations Hard

Q100. A married couple are separately assessed. Which spouse should claim their approved charitable donations?

B · Salaries tax Fringe benefits Medium

Q101. How is the following treated for salaries tax purposes?
An air ticket provided once every two years under an employment contract, for the employee to visit their home country

B · Salaries tax Fringe benefits Medium

Q102. How is the following treated for salaries tax purposes?
A low-interest loan from the employer, where the interest actually charged is below market rate but is not waived

B · Salaries tax Fringe benefits Medium

Q103. How is the following treated for salaries tax purposes?
The employer waiving repayment of an employee loan

B · Salaries tax Fringe benefits Medium

Q104. How is the following treated for salaries tax purposes?
A cash allowance paid to the employee to cover the cost of meals

B · Salaries tax Fringe benefits Medium

Q105. How is the following treated for salaries tax purposes?
Free meals provided at the employer's canteen on the business premises during working hours

B · Salaries tax Fringe benefits Medium

Q106. How is the following treated for salaries tax purposes?
A cash bonus tied to the employee remaining in service until a future date, paid after that date

B · Salaries tax Timing of income Hard

Q107. A discretionary bonus for the year ended 31 March 2026 is only decided by the board and paid in July 2026. In which year of assessment does it accrue?

B · Salaries tax Share options Medium

Q108. How is a gain on a share option granted to an employee normally taxed, where the option itself has no ascertainable market value at grant?

B · Salaries tax Share options Hard

Q109. What is the effect of the 'deemed exercise' rule where a share option remains unexercised for a long period?

B · Salaries tax MPF contributions Medium

Q110. An employee contributes to the mandatory tier of their MPF scheme. How is the deduction restricted?

B · Salaries tax One-off relief Medium

Q111. What is the nature of the one-off salaries tax reduction the Financial Secretary has announced in several recent Budgets?

B · Salaries tax Joint assessment Medium

Q112. For which taxpayer is an election for joint assessment under s.10(2) most likely to be worthwhile?

B · Salaries tax Personal allowances Hard

Q113. A couple marry partway through the year of assessment. How is the married person's allowance affected?

B · Salaries tax Personal allowances Medium

Q114. A taxpayer's child is born in November, partway through the year of assessment. How much child allowance can be claimed for that year?

B · Salaries tax Personal allowances Hard

Q115. What additional, one-off allowance is available in the year a child is born, on top of the ordinary child allowance for that child?

B · Salaries tax Personal allowances Medium

Q116. What are the basic conditions for claiming the child allowance?

C · Profits tax Charge Easy

Q117. Who is chargeable to profits tax and on what?

C · Profits tax Source Medium

Q118. How is the source of profits determined, following HK-TVB v CIR and later cases?

C · Profits tax Source - trading profits Medium

Q119. For a business of trading in goods, what is the primary factor in determining the source of the trading profit?

C · Profits tax Source - contract processing Hard

Q120. A Hong Kong company has goods manufactured under a contract-processing arrangement in the Mainland, and sells the goods from Hong Kong. How is the profit sourced?

C · Profits tax Source - service income Medium

Q121. What is the basic rule for sourcing profits from the provision of services?

C · Profits tax Badges of trade Medium

Q122. Which of the 'badges of trade' does the following describe?
A short period of ownership before resale

C · Profits tax Badges of trade Medium

Q123. Which of the 'badges of trade' does the following describe?
The taxpayer's stated intention at the time of acquisition, taken with the surrounding circumstances

C · Profits tax Badges of trade Medium

Q124. Which of the 'badges of trade' does the following describe?
The number and frequency of similar transactions

C · Profits tax Badges of trade Medium

Q125. Which of the 'badges of trade' does the following describe?
An asset acquired to be modified or improved before resale

C · Profits tax Capital vs revenue Hard

Q126. A company receives a lump sum as compensation for the permanent loss of an agency it held, the agency being a capital asset of the business. How is the receipt treated?

C · Profits tax Capital vs revenue Medium

Q127. An insurer pays out for trading stock destroyed by fire. How is the payment treated?

C · Profits tax General deduction Medium

Q128. What is the statutory test for deducting an expense under profits tax?

C · Profits tax Non-deductible expenditure Easy

Q129. Which of the following IS normally deductible under s.17?

C · Profits tax Non-deductible expenditure Medium

Q130. A trader incurs legal costs in acquiring a new shop lease for the business. How is the expenditure treated?

C · Profits tax Deductions Medium

Q131. A company incurs legal costs defending a claim brought by a customer over defective goods sold in the ordinary course of business. How are the costs treated?

C · Profits tax Donations Medium

Q132. A company's assessable profits before deducting donations are $500,000, and it made approved charitable donations of $30,000 in the year. What deduction is allowed?

C · Profits tax Donations Medium

Q133. A company's assessable profits before deducting donations are $280,000, and it made approved charitable donations of $15,000 in the year. What deduction is allowed?

C · Profits tax Donations Medium

Q134. A company's assessable profits before deducting donations are $900,000, and it made approved charitable donations of $60,000 in the year. What deduction is allowed?

C · Profits tax Repairs vs improvement Hard

Q135. A company replaces a factory's flat roof with a completely new and improved roof structure of superior design, rather than patching the original. How is the cost treated?

C · Profits tax Bad and doubtful debts Medium

Q136. A trader makes a specific provision against a named customer's debt, having reasonable grounds to believe it will not be paid. Is the provision deductible?

C · Profits tax Bad and doubtful debts Medium

Q137. A bad debt previously allowed as a deduction is unexpectedly recovered in a later year. How is the recovery treated?

C · Profits tax Interest deduction Hard

Q138. Under what condition is interest expense generally deductible against profits tax?

C · Profits tax Depreciation allowances Medium

Q139. What initial allowance is available on qualifying capital expenditure on plant or machinery?

C · Profits tax Depreciation allowances Easy

Q140. At what rates is the annual allowance on plant and machinery computed?

C · Profits tax Depreciation allowances Hard

Q141. A 30%-pool has a written-down value brought forward of $800,000. During the year the business bought qualifying plant for $200,000 and sold plant for $50,000. What is the total depreciation allowance for the year?

C · Profits tax Depreciation allowances Hard

Q142. A pool taxed at 20% has a written-down value brought forward of $1,500,000. During the year the business bought qualifying plant for $100,000 and sold plant for $300,000. What is the total depreciation allowance for the year?

C · Profits tax Depreciation allowances Hard

Q143. A pool taxed at 10% has a written-down value brought forward of $0. During the year the business bought qualifying plant for $600,000 and sold plant for $0. What is the total depreciation allowance for the year?

C · Profits tax Depreciation allowances Hard

Q144. A 30%-pool has a written-down value brought forward of $450,000. During the year the business bought qualifying plant for $150,000 and sold plant for $100,000. What is the total depreciation allowance for the year?

C · Profits tax Depreciation allowances Hard

Q145. Disposal proceeds from selling the only asset in a pool exceed its written-down value brought forward, after also deducting the year's additions. What is the tax result?

C · Profits tax Depreciation allowances - hire purchase Hard

Q146. Plant is acquired on hire purchase with a deposit of $60,000, and 6 monthly instalments are paid in the year, each with a capital element of $8,000. What initial allowance is available for the year?

C · Profits tax Depreciation allowances - hire purchase Hard

Q147. Plant is acquired on hire purchase with a deposit of $100,000, and 4 monthly instalments are paid in the year, each with a capital element of $12,000. What initial allowance is available for the year?

C · Profits tax Depreciation allowances - hire purchase Hard

Q148. Plant is acquired on hire purchase with a deposit of $40,000, and 9 monthly instalments are paid in the year, each with a capital element of $5,000. What initial allowance is available for the year?

C · Profits tax Commercial buildings allowance Medium

Q149. What allowance is available on capital expenditure on constructing a commercial building or structure used in the business?

C · Profits tax Commercial/industrial buildings allowance Hard

Q150. A company buys a completed commercial building for use in its business. On what amount is the buildings allowance computed?

C · Profits tax Prescribed fixed assets Medium

Q151. What allowance is available for capital expenditure on a prescribed fixed asset such as computer hardware and software, or manufacturing machinery specified by the Commissioner?

C · Profits tax R&D expenditure Hard

Q152. A company incurred Type A R&D expenditure of $400,000 and Type B (qualifying) R&D expenditure of $2,500,000 in the year. What total deduction is available under s.16B?

C · Profits tax R&D expenditure Hard

Q153. A company incurred Type A R&D expenditure of $0 and Type B (qualifying) R&D expenditure of $3,000,000 in the year. What total deduction is available under s.16B?

C · Profits tax R&D expenditure Hard

Q154. A company incurred Type A R&D expenditure of $600,000 and Type B (qualifying) R&D expenditure of $2,400,000 in the year. What total deduction is available under s.16B?

C · Profits tax R&D expenditure Hard

Q155. What distinguishes 'Type B' qualifying R&D expenditure from 'Type A'?

C · Profits tax Trading losses Easy

Q156. How is an unrelieved trading loss of a Hong Kong business normally treated?

C · Profits tax Trading losses Medium

Q157. A sole proprietor's business makes a loss for the year, and they also have rental income from a separate let property. How can the business loss be set against the rental income in the same year?

C · Profits tax Trading losses - partnerships Hard

Q158. How is a partnership's trading loss for a year treated?

C · Profits tax Two-tier profits tax Easy

Q159. A Hong Kong company has assessable profits of exactly $2,000,000 for the year, with no connected entities. What profits tax is payable?

C · Profits tax Two-tier profits tax - corporation Medium

Q160. A Hong Kong company (not connected with any other entity electing the two-tier regime) has assessable profits of $2,500,000 for the year. What profits tax is payable?

C · Profits tax Two-tier profits tax - corporation Medium

Q161. A Hong Kong company (not connected with any other entity electing the two-tier regime) has assessable profits of $4,200,000 for the year. What profits tax is payable?

C · Profits tax Two-tier profits tax - corporation Medium

Q162. A Hong Kong company (not connected with any other entity electing the two-tier regime) has assessable profits of $8,000,000 for the year. What profits tax is payable?

C · Profits tax Two-tier profits tax - corporation Medium

Q163. A Hong Kong company (not connected with any other entity electing the two-tier regime) has assessable profits of $12,000,000 for the year. What profits tax is payable?

C · Profits tax Two-tier profits tax Hard

Q164. How does the two-tier regime apply where several companies are 'connected entities' of one another?

C · Profits tax Two-tier profits tax - unincorporated business Medium

Q165. A sole proprietorship has assessable profits of $2,400,000. What profits tax is payable?

C · Profits tax Two-tier profits tax - unincorporated business Medium

Q166. A sole proprietorship has assessable profits of $3,600,000. What profits tax is payable?

C · Profits tax Two-tier profits tax - unincorporated business Medium

Q167. A sole proprietorship has assessable profits of $5,000,000. What profits tax is payable?

C · Profits tax Sole trader Easy

Q168. How is a sole proprietor's business profit assessed to profits tax?

C · Profits tax Sole trader Medium

Q169. A sole trader draws a monthly 'salary' from the business and records it as an expense. How is this treated in the profits tax computation?

C · Profits tax Sole trader Hard

Q170. A sole trader pays a salary to their spouse, who works full-time managing the shop. Is the salary deductible?

C · Profits tax Partnership Medium

Q171. How is a Hong Kong partnership assessed to profits tax?

C · Profits tax Partnership Hard

Q172. Partners are paid a salary and interest on capital under the partnership agreement, both charged as expenses in the partnership accounts. How are these treated for profits tax?

C · Profits tax Two-tier profits tax - mixed partnership Hard

Q173. A partnership with 3 partners has assessable profits of $3,000,000 for the year, shared 50% : 30% : 20%. One partner is a company and the rest are individuals. What is the total profits tax payable, applying the two-tier rates separately to each partner's share?

C · Profits tax Two-tier profits tax - mixed partnership Hard

Q174. A partnership with 2 partners has assessable profits of $5,000,000 for the year, shared 60% : 40%. One partner is a company and the rest are individuals. What is the total profits tax payable, applying the two-tier rates separately to each partner's share?

C · Profits tax Two-tier profits tax - mixed partnership Hard

Q175. A partnership with 3 partners has assessable profits of $4,000,000 for the year, shared 30% : 30% : 40%. One partner is a company and the rest are individuals. What is the total profits tax payable, applying the two-tier rates separately to each partner's share?

C · Profits tax Partnership - personal assessment Hard

Q176. A partnership has one individual partner and one corporate partner. How does each partner's share of the partnership profit interact with personal assessment?

C · Profits tax Partnership - personal assessment Hard

Q177. An individual partner elects personal assessment. How is interest paid by them personally to fund their share of the partnership's borrowings restricted?

C · Profits tax Common corporation Easy

Q178. At what rates is an ordinary Hong Kong company (not a qualifying professional reinsurer, corporate treasury centre or similar concessionary case) taxed on its assessable profits?

C · Profits tax Common corporation Medium

Q179. How does a company's payment of remuneration to its director, who is also its sole shareholder, differ in tax treatment from a sole trader's own drawings?

C · Profits tax Common corporation Medium

Q180. How are dividends paid by a Hong Kong company treated for profits tax purposes?

C · Profits tax Trading stock Easy

Q181. On what basis is trading stock normally valued at the end of an accounting period, for both accounting and tax purposes?

C · Profits tax Trading stock Medium

Q182. Which cost formulas are acceptable for valuing trading stock under Hong Kong tax and accounting practice?

C · Profits tax Trading stock Hard

Q183. A trader takes stock out of the business for personal use, or gives it away, without any question of trade to trade sale. How is this treated for profits tax?

C · Profits tax Basis period Easy

Q184. For an established business preparing annual accounts, what is the basis period for a year of assessment?

C · Profits tax Basis period - new business Hard

Q185. A business commences on 1 October 2025 and its first accounts are made up to 31 December 2026, a period of 15 months. What is the effect on the basis periods for the first two years of assessment?

C · Profits tax Basis period - cessation Medium

Q186. A business permanently ceases on 30 June 2026, having last made up accounts to 31 December 2025. What is the basis period for the year of assessment in which it ceases?

C · Profits tax Basis period - change of accounting date Medium

Q187. What must a business do if it wants to change its accounting year end?

C · Profits tax Provisional profits tax Medium

Q188. A company's final assessable profits for the preceding year were $2,400,000, on which the two-tier rates were applied. In the absence of any estimate supplied by the company, on what figure will provisional profits tax for the current year normally be raised?

C · Profits tax Provisional profits tax Medium

Q189. A company's final assessable profits for the preceding year were $3,200,000, on which the two-tier rates were applied. In the absence of any estimate supplied by the company, on what figure will provisional profits tax for the current year normally be raised?

C · Profits tax Provisional profits tax Medium

Q190. A company's final assessable profits for the preceding year were $6,000,000, on which the two-tier rates were applied. In the absence of any estimate supplied by the company, on what figure will provisional profits tax for the current year normally be raised?

C · Profits tax Provisional profits tax Medium

Q191. A company's actual assessable profits turn out to be much lower than the figure on which provisional profits tax was charged. How is the provisional tax reconciled once the final assessment is made?

C · Profits tax Group relief Medium

Q192. Can a loss-making Hong Kong subsidiary surrender its trading loss to a profitable fellow group company, to reduce the group's overall tax?

C · Profits tax Group relief Medium

Q193. What is the profits tax consequence of one group company charging another a management fee?

C · Profits tax Offshore claims Medium

Q194. Where a taxpayer claims that profits included in its Hong Kong accounts are in fact offshore and not chargeable, where does the burden of proof lie?

C · Profits tax Offshore claims Medium

Q195. What kind of evidence does the Inland Revenue Department expect to support an offshore profits claim?

C · Profits tax Exchange differences Hard

Q196. How is a foreign exchange gain or loss on a trade debtor denominated in a foreign currency treated for profits tax?

C · Profits tax Exchange differences Hard

Q197. A company borrows in US dollars to fund the purchase of a new factory building. An exchange loss arises when the loan is partly repaid. How is the loss treated?

C · Profits tax Pre-trading expenditure Hard

Q198. A company incurs marketing and staff recruitment costs while setting up a new business, several months before it actually starts trading. Are these costs deductible against the profits once trading begins?

C · Profits tax Post-cessation expenditure Hard

Q199. A business pays a trade debt it still owed after it permanently ceased trading. Can this expense still be deducted?

C · Profits tax Capital vs revenue Medium

Q200. A private investment holding company buys a block of shares intending to hold them long term for dividend income, and sells them years later at a large profit after an unsolicited takeover offer. How is the gain treated?

C · Profits tax Capital vs revenue Medium

Q201. A property developer, in a transaction unrelated to its normal projects, buys a plot of land, obtains planning permission to increase its value, and resells it within the year at a profit, having taken out short-term finance for the purchase. How is the profit treated?

C · Profits tax Deeming provisions Hard

Q202. A foreign company, with no other presence in Hong Kong, licenses a patent to a Hong Kong manufacturer for use in Hong Kong and receives royalties for it. How is the royalty income treated?

C · Profits tax Deeming provisions Hard

Q203. Under s.21A, what proportion of a royalty paid to a non-resident (who is not an associate of the payer) for the use of intellectual property in Hong Kong is deemed to be the assessable profit?

C · Profits tax Non-resident businesses Medium

Q204. A non-resident person carries on a trade in Hong Kong through a local agent, and profits arise here. How does IRD collect the tax if the non-resident itself has no assets or presence in Hong Kong?

C · Profits tax Double taxation relief Hard

Q205. A Hong Kong resident's profits, already taxed in a country with which Hong Kong has no comprehensive double taxation agreement, are also taxed in Hong Kong because they are (unusually) treated as Hong Kong sourced. What relief is available under s.50?

C · Profits tax Double taxation relief Hard

Q206. What is the practical effect of Hong Kong's comprehensive double taxation agreements on profits that are genuinely offshore under Hong Kong's own source rules?

C · Profits tax Interest income Medium

Q207. A Hong Kong company deposits its surplus cash with a licensed Hong Kong bank and earns interest. Is the interest chargeable to profits tax?

C · Profits tax Deductions Easy

Q208. A company insures its trading stock and premises against fire. Are the premiums deductible?

C · Profits tax Non-deductible expenditure Medium

Q209. A company is fined for breaching pollution control regulations while operating its factory. Is the fine deductible against its profits?

C · Profits tax Deductions Hard

Q210. A company contributes to a retirement scheme for the benefit of its staff. What is the deduction limit for an ordinary (non-mandatory) employer contribution?

C · Profits tax Depreciation allowances Hard

Q211. A 20%-pool has a written-down value brought forward of $300,000. During the year the business bought qualifying plant for $400,000 and sold plant for $0. What is the total depreciation allowance for the year?

C · Profits tax Depreciation allowances Hard

Q212. A 20%-pool has a written-down value brought forward of $900,000. During the year the business bought qualifying plant for $150,000 and sold plant for $200,000. What is the total depreciation allowance for the year?

C · Profits tax Depreciation allowances Medium

Q213. Who determines which of the 10%, 20% or 30% pool an item of plant or machinery falls into?

C · Profits tax Deductions Medium

Q214. A company takes out fidelity guarantee insurance against loss caused by employee dishonesty. Is the premium deductible?

D · Property tax Charge Easy

Q215. On what basis is property tax charged?

D · Property tax Assessable value Medium

Q216. What is the assessable value of a property?

D · Property tax Computation Medium

Q217. A property was let for the whole year at $25,000 a month. The owner paid rates of $9,000. The tenant paid management fees direct to the building manager. What is the property tax payable?

D · Property tax Computation Medium

Q218. A property was let for the whole year at $40,000 a month. The owner paid rates of $16,000. The tenant paid management fees direct to the building manager. What is the property tax payable?

D · Property tax Computation Medium

Q219. A property was let for the whole year at $18,000 a month. The owner paid rates of $6,500. The tenant paid management fees direct to the building manager. What is the property tax payable?

D · Property tax Computation Medium

Q220. A property was let for the whole year at $60,000 a month. The owner paid rates of $24,000. The tenant paid management fees direct to the building manager. What is the property tax payable?

D · Property tax Premium Medium

Q221. A premium of $240,000 is received on the grant of a lease for 48 months. How much is included in the assessable value for a full year?

D · Property tax Premium Medium

Q222. A premium of $300,000 is received on the grant of a lease for 60 months. How much is included in the assessable value for a full year?

D · Property tax Premium Medium

Q223. A premium of $210,000 is received on the grant of a lease for 42 months. How much is included in the assessable value for a full year?

D · Property tax Premium Medium

Q224. A premium of $480,000 is received on the grant of a lease for 72 months. How much is included in the assessable value for a full year?

D · Property tax Premium Medium

Q225. A premium of $120,000 is received on the grant of a lease for 24 months. How much is included in the assessable value for a full year?

D · Property tax Irrecoverable rent Medium

Q226. In which year of assessment is irrecoverable rent deducted?

D · Property tax Recovery of bad rent Medium

Q227. Rent previously deducted as irrecoverable is later recovered. How is it treated?

D · Property tax Rental deposit Hard

Q228. A tenant defaults and the owner forfeits and retains the rental deposit. How is the forfeited deposit treated?

D · Property tax Statutory allowance Medium

Q229. How is the statutory allowance for repairs and outgoings computed?

D · Property tax Deductions Medium

Q230. In computing net assessable value, how is the following treated?
Government rent paid by the owner

D · Property tax Deductions Medium

Q231. In computing net assessable value, how is the following treated?
Mortgage interest paid by the owner

D · Property tax Deductions Medium

Q232. In computing net assessable value, how is the following treated?
The actual cost of repairing the roof

D · Property tax Deductions Medium

Q233. In computing net assessable value, how is the following treated?
The cost of replacing air-conditioners

D · Property tax Deductions Medium

Q234. In computing net assessable value, how is the following treated?
Rates paid by the owner

D · Property tax Deductions Medium

Q235. In computing net assessable value, how is the following treated?
Rates paid by the tenant direct to the Government

D · Property tax Depreciation Hard

Q236. What depreciation allowance is available for plant installed in a property let by an individual and charged to property tax?

D · Property tax Multiple properties Medium

Q237. A taxpayer owns three let properties. How is property tax computed?

D · Property tax Corporate owners Hard

Q238. A Hong Kong company carrying on business lets a property it owns. What relief is available from property tax?

D · Property tax Set-off Hard

Q239. A company pays property tax on a let property and the rental income is also assessed to profits tax. How is the property tax relieved?

D · Property tax Chargeable person Easy

Q240. On whom is property tax charged?

D · Property tax Rent-free period Medium

Q241. A lease grants two rent-free months at the start. How are those months treated?

D · Property tax Corporate owners Hard

Q242. A company lets a property and does not apply for the s.5(2)(a) property tax exemption. It reports the rental income in its profits tax computation as well. How does the tax actually payable work out?

D · Property tax Losses Medium

Q243. A let property's outgoings (rates paid by the owner, for example) exceed the rent receivable for the year. Can the resulting 'loss' be used anywhere in the property tax system itself?

D · Property tax Assessable value Hard

Q244. A property is let to a relative at a nominal rent well below the market rate. On what value is property tax charged?

D · Property tax Lease renewal Medium

Q245. A tenancy is renewed at a materially higher rent partway through the year. How is the assessable value affected?

D · Property tax Deductions Medium

Q246. How does Government rent (as distinct from general rates) affect the property tax computation?

D · Property tax Vacant periods Medium

Q247. A property let at $20,000 a month stood genuinely vacant, with no tenant and no rent receivable, for 2 months of the year. What is the property tax payable for the year?

D · Property tax Vacant periods Medium

Q248. A property let at $35,000 a month stood genuinely vacant, with no tenant and no rent receivable, for 3 months of the year. What is the property tax payable for the year?

D · Property tax Charge Easy

Q249. Does it make any difference to the owner's property tax whether the tenant uses the property for a business, as a residence, or as a charity's office?

E · Personal assessment Nature Easy

Q250. What is personal assessment?

E · Personal assessment When it helps Medium

Q251. For which of the following can electing personal assessment produce no benefit at all?

E · Personal assessment Eligibility Easy

Q252. What is the age requirement for electing personal assessment?

E · Personal assessment Eligibility Hard

Q253. What makes a person a 'temporary resident' for personal assessment?

E · Personal assessment Eligibility Hard

Q254. From the year of assessment 2018/19, how is the residence condition satisfied?

E · Personal assessment Married couples Hard

Q255. From the year of assessment 2018/19, how may a married person elect for personal assessment?

E · Personal assessment Married couples Hard

Q256. A couple are jointly assessed under salaries tax. How must any personal assessment election be made?

E · Personal assessment Married couples Hard

Q257. Where a couple elect jointly, how is the total tax apportioned between them?

E · Personal assessment Time limits Medium

Q258. By when must an election for personal assessment be made?

E · Personal assessment Time limits Hard

Q259. By when must an election for personal assessment be withdrawn?

E · Personal assessment Deceased taxpayer Medium

Q260. A person eligible to elect for personal assessment dies before doing so. What happens to the right of election?

E · Personal assessment Computation Hard

Q261. Which figures are aggregated to arrive at total income under personal assessment?

E · Personal assessment Interest deduction Hard

Q262. How much interest on money borrowed to produce property income may be deducted under personal assessment?

E · Personal assessment Computation Hard

Q263. Tax under personal assessment is the lower of the progressive rates on net chargeable income and what?

E · Personal assessment Computation Hard

Q264. Total income under personal assessment is $1,420,000, interest to produce property income is $0, and allowances total $145,000. What is the tax payable?

E · Personal assessment Computation Hard

Q265. Total income under personal assessment is $1,058,400, interest to produce property income is $200,000, and allowances total $290,000. What is the tax payable?

E · Personal assessment Computation Hard

Q266. Total income under personal assessment is $884,000, interest to produce property income is $42,000, and allowances total $145,000. What is the tax payable?

E · Personal assessment Business losses Medium

Q267. What is the effect of electing personal assessment on a sole proprietorship loss of the year?

E · Personal assessment Business losses Hard

Q268. Can an offshore business loss be brought into a personal assessment computation?

E · Personal assessment When it helps Hard

Q269. A taxpayer with substantial salary income also owns an unmortgaged let property. Is personal assessment likely to be beneficial?

E · Personal assessment Eligibility Medium

Q270. Which of the following cannot elect for personal assessment?

E · Personal assessment Making the election Easy

Q271. How must an election for personal assessment be made?

E · Personal assessment Computation Medium

Q272. A married couple elect for personal assessment. What allowance may they claim between them for their marital status?

E · Personal assessment Computation Medium

Q273. Are child, dependent parent, dependent sibling, and disability allowances available under a personal assessment computation?

E · Personal assessment Computation Medium

Q274. Are the concessionary deductions available under salaries tax (self-education expenses, home loan interest, elderly residential care expenses, MPF contributions, approved charitable donations) also available under personal assessment?

E · Personal assessment Computation Medium

Q275. Does electing personal assessment change how income from each individual source (property, employment, business) is itself computed?

E · Personal assessment When it helps Hard

Q276. In which of the following is personal assessment LEAST likely to produce any tax saving?

E · Personal assessment Practical approach Medium

Q277. In an exam question asking whether a married couple should elect for personal assessment, what should the answer actually compare?

E · Personal assessment Business losses Hard

Q278. A sole trader's business made a loss last year (say YA 2024/25), which was simply carried forward under the profits tax computation because no election was made at the time. Can personal assessment still be used now to relieve that loss against last year's other income?

E · Personal assessment Computation Medium

Q279. In the personal assessment computation, what does 'total income' mean before it becomes 'reduced total income'?

E · Personal assessment Partnership interaction Medium

Q280. An individual partner in a mixed partnership elects personal assessment. What happens to the corporate partner's share of the same partnership's profit?

E · Personal assessment Eligibility Medium

Q281. Must a taxpayer have more than one source of chargeable income before personal assessment is worth considering?

E · Personal assessment Time limits Medium

Q282. What happens if an election for personal assessment is made after the statutory time limit in s.41(2) has passed?

ACCA TX-HKG

Question Bank — Section B

ACCA TX-HKG — Section B, OT Case Questions · 30 original questions across 6 integrated scenarios, matching the exam's own case-question format: one set of facts, five linked questions, spanning more than one syllabus area at once. A real Section B is 3 cases / 15 questions / 30 marks, so this is 2 full sittings' worth.

題庫 BACCA TX-HKG 題庫 Section B:3 個原創個案情境(合共15條相連題目,30分),仿照考試的個案題格式——同一組資料,五條相關問題,橫跨多於一個考試範疇。計分方式與 Section A 相同。

What this is

Section B mirrors the exam's real OT case format: unlike Section A's single-fact questions, each case gives one connected scenario and asks five questions against it — so an early answer (a rental value, a share of profit) often feeds directly into a later one, exactly as it would in a real case.

Same computation engine as Section A Every figure in every case was generated from and checked against scripts/qbank_tax.py, and each case's five questions were verified for internal consistency — an answer used in question 3 is the same figure question 1 or 2 established, not a fresh unrelated number.
Score: 0 / 30

Case 1 — Ms Fiona Ng (10 marks)

Fiona Ng is employed as marketing manager by Silverline Retail Ltd, a company centrally managed and controlled in Hong Kong. Her annual salary for the year of assessment 2026/27 is $960,000. Silverline provides her with a self-contained flat, rent free, for the whole year; Fiona has no outgoings deductible under s.12(1)(a) against her salary.

Separately, Fiona wholly owns a second residential flat, which she lets out (unconnected with her employer) for the whole year at $18,000 a month. She personally paid rates of $6,500 for the year on that flat. She is single and claims only the basic allowance ($145,000 for 2026/27); she has no mortgage on either property and no other income, deductions or losses.
Rental value

B001. What rental value must be included in Fiona's assessable income for the flat Silverline provides rent free?

Assessable income

B002. What is Fiona's total assessable income from her employment for the year (salary plus the rental value of the flat)?

Property tax

B003. What is the property tax payable on Fiona's own let flat for the year?

Salaries tax computation

B004. Ignoring any election for personal assessment, what is Fiona's salaries tax payable for the year?

Personal assessment

B005. Should Fiona elect personal assessment for the year?

Case 2 — Golden Horizon Ltd (10 marks)

Golden Horizon Ltd, a Hong Kong trading company, reports an accounting profit before tax of $5,000,000 for the year ended 31 March 2027. Its accounts include depreciation of $300,000 and a fine of $20,000 for a pollution control breach, and it paid $150,000 in approved charitable donations, all charged as expenses.

During the year Golden Horizon bought qualifying plant for $500,000 (the 20% pool's written-down value brought forward was $200,000, and there were no disposals), and incurred $1,000,000 of qualifying Type B R&D expenditure, which is included in the $1,000,000 already charged as an expense in arriving at the accounting profit above. The company has no connected entities for the two-tier regime.
Depreciation allowances

B006. What is the total depreciation allowance available on the plant pool for the year?

R&D deduction

B007. Beyond the $1,000,000 already charged as an expense in the accounts, what additional deduction is available for the qualifying Type B R&D expenditure?

Donations

B008. What is the maximum charitable donation deduction Golden Horizon may claim?

Assessable profit

B009. What is Golden Horizon's assessable profit for the year?

Two-tier profits tax

B010. What is Golden Horizon's profits tax payable for the year?

Case 3 — Harbour Partners (10 marks)

Harbour Partners is a Hong Kong partnership with two partners: Mr Tam, an individual, holding a 60% profit share, and Silver Bay Ltd, a corporate partner, holding the remaining 40%. The partnership's assessable profit for the year is $4,000,000, allocated in that profit-sharing ratio, with each partner's two-tier $2,000,000 band apportioned in the same ratio.

Mr Tam's own tax on his share remained unpaid more than six months after the due date - specifically 7 months overdue when he finally settled it.
Partnership allocation

B011. What is Mr Tam's share of the partnership's assessable profit?

Corporate partner's tax

B012. What is Silver Bay Ltd's own profits tax payable on its 40% share, applying the two-tier rates to its apportioned band?

Individual partner's tax

B013. What is Mr Tam's own profits tax payable on his 60% share, applying the two-tier rates to his apportioned band?

Total partnership tax

B014. What is the total profits tax payable in respect of Harbour Partners' profit for the year?

Late payment surcharge

B015. Mr Tam's own tax of $270,000 on his share was paid 7 months after the due date. What is the total amount he actually had to pay, including surcharges?

Case 4 — Lau's Trading (10 marks)

Kenneth Lau runs Lau's Trading as a sole proprietorship. Its accounts for the year show a net profit of $1,800,000, after charging the following as expenses: a monthly “salary” of $50,000 drawn by Kenneth himself ($600,000 for the year), a salary of $240,000 paid to his wife, who works full time managing the shop, and depreciation of $80,000.

Depreciation allowances for the year have been computed at $120,000. Kenneth also made the mandatory MPF contribution of $18,000 in respect of himself as a self-employed person; this was not charged in the accounts above.
s.17(2) payments to the proprietor

B016. How much must be added back in respect of the salaries paid to Kenneth and to his wife?

s.16AA MPF deduction

B017. What deduction may the business claim for Kenneth's own mandatory MPF contribution as a self-employed person?

Assessable profit

B018. What is Lau's Trading's assessable profit for the year?

Two-tier profits tax

B019. What is the profits tax payable by Lau's Trading?

Loss relief

B020. Suppose instead that Lau's Trading had made a loss for the year, and Kenneth also had salary income from a part-time job. What could he do to relieve the loss against that salary in the same year?

Case 5 — Ms Priya Sharma (10 marks)

Priya Sharma has a Hong Kong employment with an annual salary of $1,200,000 for the year of assessment 2026/27.

During the year she exercised a share option granted to her by her employer in an earlier year. The market value of the shares on the date of exercise was $850,000 and she paid the exercise price of $500,000. On completing her fixed-term contract she also received a gratuity of $200,000, payable under the terms of that contract.

She paid $135,000 of mortgage interest on the flat she lives in herself, and made the mandatory MPF contribution of $18,000. She is married and her husband has no income; the married person's allowance is $290,000.
Share options

B021. What amount of the share option gain is assessable to salaries tax?

Termination payments

B022. How is the $200,000 contract-completion gratuity treated?

Home loan interest

B023. What deduction may Priya claim for the $135,000 of home loan interest?

Net income

B024. What is Priya's net income for the year, after deductions but before allowances?

Salaries tax payable

B025. What is Priya's salaries tax payable for the year?

Case 6 — Mr Wong Kwok-keung (10 marks)

Wong Kwok-keung owns two properties in Hong Kong, both let in his own name.

Flat A was let for the whole year at $30,000 a month. Wong paid rates of $12,000 on it. The tenant defaulted and $60,000 of the year's rent was proved to be irrecoverable during the year.

Flat B was let under a new four-year lease granted at the start of the year, for which Wong received a premium of $360,000. No periodic rent is payable on Flat B, and the tenant pays the rates on it direct to the Government.
Irrecoverable rent

B026. What is the assessable value of Flat A for the year, before deducting rates and the statutory allowance?

Flat A property tax

B027. What is the property tax payable on Flat A?

Lease premium

B028. How much of Flat B's premium falls into the assessable value for this year?

Total property tax

B029. What is Wong's total property tax liability for the year on both properties?

Corporate owners

B030. Suppose Flat B were instead owned by a Hong Kong company carrying on business here. What relief from property tax would be available?

ACCA TX-HKG

Question Bank — Section C

ACCA TX-HKG — Section C, Constructed Response Questions · 8 original long-form questions (four 15-mark and four 25-mark), matching the exam's own format — full scenario, a graded model answer laid out as a real computation, and marks allocated line by line. A real Section C is one 15-mark and one 25-mark question, so this is 4 full sittings' worth, covering salaries tax, profits tax, property tax, partnerships, badges of trade, depreciation allowances, offshore claims and IRD administration.

題庫 CACCA TX-HKG 題庫 Section C:2 條原創長題目(15分及25分),仿照考試格式——完整情境、附詳細評分準則的計算過程模範答案。

What this is

Section C mirrors the exam's constructed-response questions: no multiple choice here — each question gives a scenario and asks you to prepare an actual computation or a written explanation, the same way you would in the exam itself. Attempt each part on paper first, then open the model answer to mark your own work.

Same computation engine as Sections A and B Every figure in all eight model answers was generated from and checked against scripts/qbank_tax.py, the same module behind Section A's and Section B's answers — nothing here was worked out by hand and left unchecked.

Question 1 — Mr Ivan Ho (15 marks)

Scenario15 marks

Ivan Ho is employed on an annual salary of $1,020,000 for the year of assessment 2026/27. During the year he incurred $60,000 on a job-related course, qualifying as a deductible self-education expense, and made the mandatory MPF contribution of $18,000. He is married; his wife has no income of her own.

Ivan also wholly owns a separate residential flat, which he lets out unconnected with his employment. Its net assessable value for the year (after rates and the 20% statutory allowance) is $200,000. He pays mortgage interest of $150,000 a year on the loan used to acquire that flat.

(a) Compute Ivan's salaries tax liability for the year, ignoring any election for personal assessment. (10 marks)

(b) Advise, with supporting calculations, whether Ivan should elect personal assessment for the year. (5 marks)

Show model answer
(a) Ivan Ho — Salaries Tax Computation, YA 2026/27
Salary1,020,000
Less: self-education expenses (1 mark)(60,000)
Less: mandatory MPF contribution (1 mark)(18,000)
Net income942,000
Less: married person's allowance (1 mark)(290,000)
Net chargeable income652,000
Tax payable — lower of two methods
Progressive rates on $652,000 (3 marks)
2%/6%/10%/14% on four $50,000 bands ($16,000) + 17% on the $452,000 remainder ($76,840)
92,840
Standard rate on net income before allowances: $942,000 × 15% (2 marks)141,300
Salaries tax payable (the lower of the two) (2 marks)92,840

Total for part (a): 10 marks. Using the standard rate on net income after allowances ($652,000 × 15% = $97,800) instead of before them, is the single commonest way to lose the 2 marks on the comparison.

(b) Without electing personal assessment
Salaries tax (from part (a))92,840
Property tax: $200,000 × 15% (1 mark)30,000
Total tax122,840
Electing personal assessment
Total income (net income $942,000 + property NAV $200,000)1,142,000
Less: mortgage interest, capped at that property's own NAV of $200,000 (2 marks)(150,000)
Reduced total income992,000
Less: married person's allowance(290,000)
Net chargeable income702,000
Progressive rates: $16,000 + ($502,000 × 17%)101,340
Standard rate on reduced total income: $992,000 × 15%148,800
Tax payable under personal assessment (the lower) (1 mark)101,340

Advice (1 mark): Ivan should elect personal assessment. It saves $122,840 − $101,340 = $21,500, because the election lets his mortgage interest on the let property (which property tax alone cannot deduct) shelter his aggregated income. Total for part (b): 5 marks.

Question 2 — XYZ Trading Ltd (25 marks)

Scenario25 marks

XYZ Trading Ltd, a Hong Kong company with no connected entities, reports a net profit per accounts of $8,000,000 for the year ended 31 March 2027. The accounts include depreciation of $450,000, approved charitable donations of $200,000, and legal fees of $60,000 for acquiring a new five-year retail lease.

The company's plant and machinery pool (20% pool) had a written-down value brought forward of $600,000; during the year it bought qualifying plant for $800,000 and sold plant for $100,000. Separately, it incurred $1,500,000 of qualifying Type B R&D expenditure, already charged as an expense (and so already included) in the $8,000,000 net profit above. The company also has an unrelieved trading loss of $500,000 brought forward from an earlier year.

(a) Compute XYZ Trading Ltd's profits tax payable for the year. (20 marks)

(b) XYZ Trading Ltd is considering whether the $500,000 loss could instead be surrendered to a profitable fellow group company. Advise, with reasons. (5 marks)

Show model answer
(a) XYZ Trading Ltd — Profits Tax Computation, YA 2026/27
Net profit per accounts8,000,000
Add: non-allowable items
Depreciation (1 mark)450,000
Charitable donations (1 mark)200,000
Legal fees — capital, acquiring a new lease (2 marks)60,000
8,710,000
Less: additional R&D deduction (4 marks)
Type B enhanced deduction: min($1,500,000, $2,000,000) × 300% = $4,500,000 total, less the $1,500,000 already expensed = $3,000,000 additional
(3,000,000)
Less: depreciation allowances (4 marks)
IA: $800,000 × 60% = $480,000. Pool: $600,000 + $800,000 − $480,000 − $100,000 disposal = $820,000. AA: $820,000 × 20% = $164,000. Total $480,000 + $164,000
(644,000)
Profit before loss brought forward5,066,000
Less: loss brought forward (1 mark)(500,000)
Profit before donations (Z)4,566,000
Less: approved charitable donations (2 marks)
lower of $200,000 actual and 35% × $4,566,000 = $1,598,100 — fully allowable
(200,000)
Assessable profit4,366,000
Tax payable
First $2,000,000 at 8.25% (2 marks)165,000
Remaining $2,366,000 at 16.5% (2 marks)390,390
Profits tax payable555,390

Total for part (a): 20 marks. Stating the total enhanced R&D deduction ($4,500,000) instead of the additional amount still to be deducted ($3,000,000), and computing the annual allowance on the pool before deducting the initial allowance, are the two errors this question is designed to catch.

(b) (5 marks): Hong Kong has no group loss relief of any kind. Each company, including XYZ Trading Ltd and any fellow group company, is a separate person chargeable to profits tax in its own right (2 marks). The $500,000 loss cannot be surrendered to, or set off against, a fellow group company's profits, however profitable that company is or however closely the two are connected (2 marks). The loss simply remains within XYZ Trading Ltd itself, carried forward indefinitely with no time limit, to be set off only against XYZ's own future assessable profits from the same trade (1 mark).

Question 3 — Mr Anthony Cheung (15 marks)

Scenario15 marks

Anthony Cheung owns two properties in Hong Kong, both let in his own name during the year of assessment 2026/27.

The shop was let for the whole year at $45,000 a month. Anthony paid rates of $20,000 on it. The tenant fell into difficulty and three months' rent was proved irrecoverable during the year.

The flat was let for the whole year at $22,000 a month, and Anthony also received a premium of $540,000 on granting that five-year lease at the start of the year. The flat's tenant pays the rates direct to the Government.

(a) Compute Anthony's property tax liability for the year. (11 marks)

(b) Anthony is considering transferring both properties into a Hong Kong company he owns, which carries on a trading business here. Explain the property tax consequences. (4 marks)

Show model answer
(a) Anthony Cheung — Property Tax Computation, YA 2026/27 — the shop
Rent receivable ($45,000 × 12)540,000
Less: irrecoverable rent ($45,000 × 3) (2 marks)(135,000)
Assessable value405,000
Less: rates paid by the owner (1 mark)(20,000)
385,000
Less: 20% statutory allowance (1 mark)(77,000)
Net assessable value308,000
Property tax at 15% (1 mark)46,200
(a) continued — the flat
Rent receivable ($22,000 × 12)264,000
Add: premium spread (3 marks)
$540,000 over the lease term or 36 months, whichever is shorter — the lease runs 60 months, so the cap bites: $540,000 ÷ 36 × 12
180,000
Assessable value444,000
Less: rates (1 mark)
nil — the tenant pays them direct, so there is nothing for the owner to deduct
—
Less: 20% statutory allowance(88,800)
Net assessable value355,200
Property tax at 15% (1 mark)53,280
Total
Shop46,200
Flat53,280
Total property tax payable (1 mark)99,480

Total for part (a): 11 marks. Each property is computed separately, with its own rates deduction and its own 20% allowance — aggregating the two into one computation loses marks. Spreading the premium over the full 60 months (giving $108,000) instead of applying the 36-month cap is the other error this question tests.

(b) (4 marks): A corporation carrying on a trade or business in Hong Kong may apply under s.5(2)(a) for exemption from property tax, on the basis that the rental income is instead brought into its profits tax computation (2 marks). If no such application is made, property tax is charged on the company in the ordinary way, but s.25 then sets that property tax off against the profits tax payable, so the same rent is not taxed twice either way (1 mark). Note the rate difference this creates: the rental profit would move from the flat 15% property tax charge to the corporate two-tier profits tax rates of 8.25%/16.5%, and the company could then deduct actual outgoings such as mortgage interest and repairs rather than being confined to the fixed 20% statutory allowance (1 mark).

Question 4 — Summit & Vale Partners (25 marks)

Scenario25 marks

Summit & Vale Partners is a Hong Kong partnership with two partners: Mr Vale, an individual, holding a 70% profit share, and Summit Holdings Ltd, a Hong Kong company, holding the remaining 30%.

The partnership's accounts for the year ended 31 March 2027 show a net profit of $6,400,000, after charging: a partner's salary of $900,000 paid to Mr Vale, a salary of $300,000 paid to Mr Vale's spouse (who works in the business), depreciation of $350,000, and approved charitable donations of $120,000.

The partnership's 30% plant and machinery pool had a written-down value brought forward of $500,000. During the year it bought qualifying plant for $900,000 and sold plant for $400,000.

(a) Compute the partnership's assessable profit for the year. (14 marks)

(b) Compute the profits tax payable by each partner, and in total. (8 marks)

(c) Mr Vale asks whether Summit Holdings Ltd could elect personal assessment on its share. Advise. (3 marks)

Show model answer
(a) Summit & Vale Partners — Assessable Profit, YA 2026/27
Net profit per accounts6,400,000
Add: non-allowable items
Partner's salary — Mr Vale (2 marks)900,000
Salary to the partner's spouse (2 marks)300,000
Depreciation (1 mark)350,000
Charitable donations (1 mark)120,000
8,070,000
Less: depreciation allowances (5 marks)
IA: $900,000 × 60% = $540,000. Pool: $500,000 + $900,000 − $540,000 − $400,000 disposal = $460,000. AA: $460,000 × 30% = $138,000. Total $540,000 + $138,000
(678,000)
Profit before donations7,392,000
Less: approved charitable donations (2 marks)
lower of $120,000 actual and 35% × $7,392,000 = $2,587,200 — fully allowable
(120,000)
Assessable profit7,272,000

Total for part (a): 14 marks. Both the partner's own salary and the salary to his spouse are added back under s.17(2) — a partnership cannot deduct either, and forgetting the spouse's salary is the commonest omission. Computing the annual allowance on the pool before deducting the initial allowance is the other error tested here.

(b) Profits tax payable — each partner's own share and rate
Mr Vale — individual, 70%
Share of assessable profit ($7,272,000 × 70%)5,090,400
Apportioned first-tier band ($2,000,000 × 70%) at 7.5% (2 marks)105,000
Balance ($5,090,400 − $1,400,000 = $3,690,400) at 15% (2 marks)553,560
Mr Vale's profits tax658,560
Summit Holdings Ltd — corporate, 30%
Share of assessable profit ($7,272,000 × 30%)2,181,600
Apportioned first-tier band ($2,000,000 × 30%) at 8.25% (2 marks)49,500
Balance ($2,181,600 − $600,000 = $1,581,600) at 16.5% (1 mark)260,964
Summit Holdings Ltd's profits tax310,464
Total profits tax payable (1 mark)969,024

Total for part (b): 8 marks. The $2,000,000 two-tier band is apportioned between the partners in the profit-sharing ratio, and each partner's slice is then taxed at their own rates — 7.5%/15% for the individual, 8.25%/16.5% for the corporate partner. Applying one flat set of rates to the whole $7,272,000, as if the partnership were a single taxpayer, is the error a mixed partnership is set to catch.

(c) (3 marks): No. Personal assessment is available to individuals only (1 mark). Summit Holdings Ltd is a company, so its share of the partnership's assessable profit simply stays in its own profits tax computation at the corporate rates, with no personal assessment route available to it (1 mark). Mr Vale, being an individual, could elect on his own share — but on these figures it would not help him: his share alone far exceeds the level at which the 17% marginal progressive rate overtakes the 15% standard rate, and there is no loss or interest here for the election to unlock (1 mark).

Question 5 — Mr Daniel Lau (15 marks)

Scenario15 marks

Daniel Lau is an individual resident in Hong Kong. In May 2026 he bought three adjacent mini-storage units in Kwun Tong for $3,200,000. He paid stamp duty and legal costs of $120,000 and spent $280,000 partitioning, repainting and installing access controls. He borrowed to fund the purchase and paid $180,000 interest during the holding period.

The units were never used by Daniel or let to tenants. He placed online advertisements for a resale before the renovation works were completed and sold all three units in February 2027 for $4,350,000, paying selling agency and legal costs of $90,000. Daniel says the gain is capital because he originally described the units as a "long-term store of value".

(a) Explain whether the gain is more likely to be taxable as profits from trade or non-taxable as capital. (10 marks)

(b) Assuming the gain is taxable as trading profits, compute Daniel's assessable profit and profits tax payable for YA 2026/27. (5 marks)

Show model answer

(a) (10 marks): The issue is whether Daniel was carrying on an adventure in the nature of trade, so that the profit arises from a trade, profession or business carried on in Hong Kong and is chargeable under s.14 (1 mark). Intention is relevant but is judged objectively from the facts, not merely from Daniel's label (1 mark). The subject matter points towards trade: three adjacent units are more consistent with a resale package than a personal long-term investment (1 mark). The short period of ownership, from May 2026 to February 2027, is a strong badge of trade (1 mark). The renovation and access-control works improved the units for onward sale rather than for own use or rental yield (1 mark). The early online advertisements, before completion of the works, show a pre-existing resale plan (1 mark). Borrowing and interest exposure support a need for quick realisation rather than passive holding (1 mark). There was no rental income or own use during the holding period, so there is little evidence of investment exploitation (1 mark). The buying, improving and selling activity was carried out in Hong Kong, so the source of any trading profit is Hong Kong (1 mark). On balance, the gain is more likely a taxable trading profit, and Daniel bears the practical burden of supporting any capital-gain claim if challenged (1 mark).

(b) Daniel Lau — Trading Profit and Profits Tax, YA 2026/27
Sale proceeds (1 mark)4,350,000
Less: purchase cost (1 mark)(3,200,000)
Less: stamp duty and legal costs (1 mark)(120,000)
Less: renovation and access controls(280,000)
Less: interest and selling costs(270,000)
Assessable profits (1 mark)480,000
Profits tax at the individual first-tier rate, $480,000 × 7.5% (1 mark)36,000

Total for part (b): 5 marks. This question is designed to catch the error of treating a self-serving "capital intention" statement as decisive, instead of weighing the badges of trade objectively.

Question 6 — JadeTech Manufacturing Ltd (25 marks)

Scenario25 marks

JadeTech Manufacturing Ltd is a Hong Kong manufacturing company with no connected entities. Its net profit per accounts for the year ended 31 March 2027 is $7,850,000, after charging depreciation of $740,000 and approved charitable donations of $260,000, and after crediting an accounting gain of $450,000 on the sale of its old factory.

The old factory had qualifying construction cost of $2,400,000. Before the sale, total industrial building allowances granted were $1,152,000 and the residue of expenditure was $1,248,000. The sale proceeds attributable to the building, excluding land, were $1,560,000.

The 30% plant and machinery pool had written-down value brought forward of $520,000. During the year JadeTech bought qualifying plant for cash of $900,000 and sold pooled plant for $180,000. It also acquired a machine on hire purchase: deposit paid $240,000, eight instalments paid in the year, and the capital element of each instalment was $55,000.

During the year JadeTech completed and first used a new factory. The purchase price included land of $2,100,000 and qualifying construction cost of $4,200,000.

(a) Compute JadeTech's assessable profits and profits tax payable for YA 2026/27. (22 marks)

(b) State three depreciation-allowance errors this question is designed to catch. (3 marks)

Show model answer
(a) JadeTech Manufacturing Ltd — Profits Tax Computation, YA 2026/27
Net profit per accounts (1 mark)7,850,000
Add back / deduct accounting and tax adjustments
Depreciation, non-deductible under s.17(1)(c) (1 mark)740,000
Approved charitable donations added back first (1 mark)260,000
Less: accounting gain on factory sale, capital receipt(450,000)
Add: industrial building balancing charge (3 marks)
Proceeds $1,560,000 less residue $1,248,000 = $312,000, capped by prior allowances of $1,152,000
312,000
Adjusted profit before depreciation allowances8,712,000
Less: depreciation allowances
30% plant pool (4 marks)
IA: $900,000 × 60% = $540,000. Pool: $520,000 + $900,000 − $540,000 − $180,000 = $700,000. AA: $700,000 × 30% = $210,000
(750,000)
Hire-purchase machine (3 marks)
Qualifying capital paid: $240,000 + (8 × $55,000) = $680,000. IA $408,000 and AA $81,600
(489,600)
New factory industrial building allowance (3 marks)
Land $2,100,000 excluded. Construction cost $4,200,000: IA 20% = $840,000; AA 4% = $168,000
(1,008,000)
Profit before donations (1 mark)6,464,400
Less: approved charitable donations (2 marks)
Actual $260,000 is below the 35% cap of $2,262,540
(260,000)
Assessable profits (1 mark)6,204,400
Profits tax: first $2,000,000 at 8.25%, balance $4,204,400 at 16.5% (1 mark)858,726

Total for part (a): 22 marks. The tax payable is $165,000 + $693,726 = $858,726.

(b) (3 marks): The first error is giving building allowances on land: only qualifying construction cost is used (1 mark). The second is computing initial allowance on the full hire-purchase cash price instead of the capital sums actually paid in the year (1 mark). The third is omitting the balancing charge on the old factory sale and taxing the accounting gain instead (1 mark).

Question 7 — Harbor Link Sourcing Ltd (15 marks)

Scenario15 marks

Harbor Link Sourcing Ltd is incorporated and managed in Hong Kong. During the year ended 31 March 2027 it earned net sourcing commission profit of $3,200,000 from overseas customers who bought electronic components from factories in Mainland China.

Harbor Link's Hong Kong staff found suppliers, negotiated prices and specifications, arranged purchase orders and dealt with quality complaints from its office in Hong Kong. Factory visits and shipment inspections in Mainland China were carried out by independent contractors engaged job by job. Customers signed their master supply agreements outside Hong Kong and paid Harbor Link into an overseas bank account.

(a) Advise whether Harbor Link's offshore claim is likely to succeed. (10 marks)

(b) If the whole profit is taxable in Hong Kong, compute the profits tax payable. (5 marks)

Show model answer

(a) (10 marks): The charge under s.14 is on profits arising in or derived from Hong Kong from a trade, profession or business carried on here (1 mark). The company carries on business in Hong Kong: it is incorporated and managed here and its staff conduct the sourcing business from the Hong Kong office (1 mark). Source is decided by identifying the profit-producing operations and where those operations take place, not by asking where the customer is resident or where money is banked (1 mark). For a sourcing commission business, the relevant operations are finding suppliers, negotiating price and specifications, arranging purchase orders and handling performance problems (2 marks). Those core operations were performed by Harbor Link's own staff in Hong Kong (1 mark). The Mainland factory visits and inspections were ancillary execution work, and they were performed by independent contractors rather than by Harbor Link's own profit-producing team (1 mark). Signing master agreements outside Hong Kong is not decisive if the commercial work that earned the commission was done in Hong Kong (1 mark). The overseas bank account is administrative evidence, not a source rule (1 mark). Harbor Link bears the burden of proving the facts supporting an offshore claim under s.68(4); on these facts the claim is unlikely to succeed (1 mark).

(b) Harbor Link Sourcing Ltd — Profits Tax if the Offshore Claim Fails, YA 2026/27
Assessable profits3,200,000
First $2,000,000 at 8.25% (2 marks)165,000
Balance $1,200,000 at 16.5% (2 marks)198,000
Profits tax payable (1 mark)363,000

Total for part (b): 5 marks. This question is designed to catch the error of treating overseas customers, overseas signing or an overseas bank account as decisive, instead of applying the operations test to the profit-producing activities.

Question 8 — East Point Design Ltd (25 marks)

Scenario25 marks

East Point Design Ltd filed its profits tax return late after omitting a major service invoice. The Inland Revenue Department later issued an additional assessment on 15 August 2027, showing tax undercharged of $420,000, and requiring payment on 15 September 2027. East Point accepts that the invoice was taxable but says the omission was caused by a bookkeeper's spreadsheet error.

The directors are considering an objection because they also believe a separate deduction has been refused wrongly. They cannot pay the full assessment by the due date and expect cash will not be available until eight months after the due date.

(a) Explain the objection procedure and what East Point must do if it wants collection held over. (10 marks)

(b) Compute the maximum penalty under s.80 and the late-payment amount if the tax remains unpaid for eight months. (8 marks)

(c) Advise on the penalty exposure and the practical steps East Point should take now. (7 marks)

Show model answer

(a) (10 marks): A valid objection must be made in writing to the Commissioner within one month after the notice of assessment, stating precisely the grounds of objection (2 marks). Filing an objection does not by itself suspend collection: the tax remains payable unless the Commissioner orders holdover (2 marks). East Point should therefore request holdover at the same time, explaining the disputed deduction and providing supporting documents (2 marks). Holdover may be conditional, including requiring the taxpayer to purchase a tax reserve certificate or provide security (1 mark). If the objection is determined against East Point, the company may appeal to the Board of Review within one month after the determination (1 mark). The accepted omitted invoice should not be included in the objection grounds: East Point should separate the conceded undercharge from the genuinely disputed deduction (1 mark). Missing the payment date without holdover exposes the company to late-payment surcharges even while correspondence continues (1 mark).

(b) East Point Design Ltd — Penalty and Late-Payment Exposure
Tax undercharged / additional tax assessed420,000
Maximum s.80 penalty: $10,000 plus treble the tax undercharged (3 marks)1,270,000
First surcharge for late payment: 5% of $420,000 (1 mark)21,000
Further surcharge after six months: 10% of $441,000 (2 marks)44,100
Total surcharges after eight months65,100
Amount payable after eight months (2 marks)485,100

Total for part (b): 8 marks. The late-payment computation applies the second 10% surcharge to the tax plus the first surcharge, not to the original tax alone.

(c) (7 marks): The omission of taxable income creates penalty exposure even if the bookkeeper made the spreadsheet error: the company remains responsible for the correctness of its return (1 mark). A maximum s.80 penalty is not automatically imposed; IRD will consider culpability, cooperation, voluntary disclosure, previous compliance and whether prosecution or additional tax procedures are used (2 marks). East Point should make a full written disclosure of the omitted invoice, correct the computation, explain the control failure and provide evidence that the error was not deliberate (1 mark). It should pay the undisputed part as soon as possible, or at least seek instalment arrangements, because cash difficulty does not remove statutory surcharges (1 mark). It should support the disputed deduction with invoices, contracts, board approvals and accounting records, and keep the objection focused on that point (1 mark). Finally, it should improve controls over sales cut-off and return review before the next filing, since repeated errors aggravate penalties (1 mark).

Revision aid — one page, every format

Computation Formats

The standard pro-forma layout for each Hong Kong tax, in the order the lines belong, with what goes on each line and one worked example apiece.

計算格式五種稅的標準計算格式集於一頁:物業稅、薪俸稅、利得稅、摺舊免稅額及個人入息課稅,逐行說明並各配一條例題。格式取自教科書,並已對照稅務局核新。
Where these come from The layouts follow Hong Kong Taxation and Tax Planning (22nd ed., Ho & Mak) — Ch.7 property tax, Ch.12 salaries tax, Ch.20 profits tax, Ch.31 plant and machinery. That book states the law to 31 May 2024, so every rate and allowance has been re-checked against IRD and updated where it has moved. § What has changed lists each difference rather than silently absorbing it.

How to use these

A tax computation is marked on structure as much as on arithmetic. Getting a figure into the wrong line — or the right figure in the right line but the wrong order — loses the marks even when the final number is close. These are the skeletons to have in your head before you start writing.

ConventionMeaning
XA figure goes here. Letters (A, B, Y, ZB…) mark subtotals that a later line refers back to.
IndentationIndented lines are workings feeding the subtotal on the right; they do not themselves enter the main column.
Single ruleA subtotal.
Double ruleA figure the question asks for, or one that carries into the next stage.
Three rules that apply to every computation here
  1. Head the computation. Taxpayer name, which tax, and the year of assessment. Three lines, and they are marks.
  2. Show the working, not just the answer. ($30,000 × 12) beside the figure earns the mark even if the arithmetic slips.
  3. Name every subtotal correctly. "Assessable value", "net assessable value", "assessable profit", "net assessable profit", "net chargeable income" are defined terms with different meanings. They are not interchangeable.

1. Property Tax IRO ss.5, 5B, 7C — textbook Ch.7

Property Tax Computation · Year of Assessment 20XX/XX
Rent receivableX
Premium, spread over the lease termX
Service charges / management fees borne by the tenant and paid to the ownerX
Recovery of rent previously written off as irrecoverableX
Less: irrecoverable rent of the year(X)
Assessable valueX
Less: rates paid by the owner(X)
X
Less: statutory allowance for repairs and outgoings, 20% of the above(X)
Net assessable valueX
Property tax at the standard rate, 15%X
LineWhat belongs there
PremiumSpread evenly over the lease term, capped at 36 months (s.5B(4)). A 3-year lease premium received in one year is taxed 12⁄36 in each.
Irrecoverable rentDeducted in the year it is recognised as irrecoverable, not the year the rent accrued (s.7C(1)). Recovery later is assessable in the year of recovery, not related back.
RatesOnly rates paid by the owner. Rates paid by the tenant never enter the computation.
20% statutory allowanceFixed, automatic, and taken after rates. It is not a claim and no receipts are needed — and no more can be claimed however much was actually spent.
The four things that never get deducted Government rent, mortgage interest, actual repairs, and improvements are all non-deductible under property tax. The 20% allowance is the only relief for outgoings. Mortgage interest is exactly why a mortgaged property owner should look at Personal Assessment.
Worked example Textbook Example 7.1 (Mr Gap), p.101 — rate unchanged, so still current

Mr Gap let a Sai Kung house on a three-year lease from 1 January 2022 at $30,000 a month, with a premium of $180,000 payable on 1 January 2022. In the year ended 31 March 2024 he paid Government rent $10,800, mortgage interest $110,000, rates $18,000, and repairs and improvement $20,000.

Mr Gap — Property Tax Computation · Year of Assessment 2023/24
Rent ($30,000 × 12)360,000
Premium ($180,000 × 12⁄36)60,000
Assessable value420,000
Less: rates paid by owner(18,000)
402,000
Less: statutory deduction ($402,000 × 20%)(80,400)
Net assessable value321,600
Property tax ($321,600 × 15%)48,240

Government rent $10,800, interest $110,000 and repairs $20,000 — $140,800 of real cash cost — get no deduction at all. That is the point of the example.

Property Tax rules → · more worked illustrations →

2. Salaries Tax IRO ss.8–13 — textbook Ch.12

The structural point worth memorising There is no statutory format for a salaries tax computation. But the layout below puts every item affecting rental value before the rental value line — because rental value is 10% of income after allowable outgoings. Lay it out any other way and you will compute rental value on the wrong base.
Salaries Tax Computation · Year of Assessment 20XX/XX
SalariesA
Bonus, commission, gratuityB
Allowances (cash or convertible into cash)C
D
Less: allowable expenses — s.12(1)(a)
Travelling from office to officeE
Professional subscriptionF(G)
Income after allowable outgoingsH
Add: rental value of employer-provided quarters (H × 10%)J
Less: rent suffered (rent paid by employee − rent refunded)(K)L
M
Add: lump sum on termination of employmentN
Add: gain on exercise of share optionO
P
Less: self-education expenses — s.12(1)(e)(Q)
Net assessable income, before concessionary deductionsR
Less: concessionary deductions
Approved charitable donations (max 35% of P)S
Elderly residential care expensesT
Home loan interestU
Mandatory contributions to MPF / recognised schemeV
VHIS premiumsW
Qualifying annuity premiums and MPF voluntary contributionsX
Domestic rentsY
Assisted reproductive service expensesZ(ZA)
Net income (net assessable income after concessionary deductions)ZB
Less: personal allowances
Basic / married person's allowanceAA
Child allowanceBB
Dependent parent and other allowancesCC(DD)
Net chargeable incomeEE
Then compute the tax twice and pay the lower
(b) Progressive rates on EE: 2% / 6% / 10% / 14% on the first four $50,000 bands, then 17%b
(c) Standard rate on ZB (net income, before personal allowances) — s.13(2)c
Salaries tax liability = the lower of (b) and (c)X
Updated: the standard rate is two-tiered from 2024/25 The textbook's format shows the standard rate as a flat 15%. From YA 2024/25 the standard rate is two-tiered: 15% on the first HKD 5,000,000 of net income, 16% on the remainder. Under HKD 5,000,000 the book's line still gives the right answer; above it, the book understates. Write line (c) as the two-tier calculation.
LineWhat catches people out
Rental value base (H)10% of income after s.12(1)(a) outgoings — not of gross salary. 4% for a hotel room / shared boarding-type accommodation, 8% for two rooms in a hotel.
Rent suffered (K)Deducted from rental value, and only down to nil — it cannot create a negative.
Donations cap (S)35% of P — income after the outgoings and rental value but before self-education and the other concessionary deductions.
Order of Q and S–ZSelf-education is a s.12 deduction and comes before the concessionary block. Putting it among the concessionary deductions changes the donations cap base.
The standard-rate base (ZB)Net income before personal allowances. Applying it to EE is the single most common error in this computation.
Worked example Built on the textbook's Ch.12 layout, at YA 2026/27 rates

Mr Pak earns salary $900,000 and a bonus $100,000, pays a professional subscription of $2,000, and is provided with a rent-free flat by his employer. He donated $30,000 to an approved charity and made mandatory MPF contributions of $18,000. He is single with no dependants.

Mr Pak — Salaries Tax Computation · Year of Assessment 2026/27
Salary and bonus1,000,000
Less: professional subscription — s.12(1)(a)(2,000)
Income after allowable outgoings (H)998,000
Add: rental value ($998,000 × 10%)99,800
Net assessable income before concessionary deductions1,097,800
Less: approved charitable donations (well under the 35% cap)(30,000)
Less: mandatory MPF contributions (capped at 18,000)(18,000)
Net income (ZB)1,049,800
Less: basic allowance D26 exam (YA 2025/26): $132,000(145,000)
Net chargeable income (EE)904,800
(b) Progressive on 904,800: 1,000 + 3,000 + 5,000 + 7,000 + (704,800 × 17%)135,816
(c) Standard rate on net income 1,049,800 × 15% (under the 5,000,000 threshold)157,470
Tax payable — the lower135,816

Note the rental value is $99,800, not $100,000 — 10% of income after the subscription, not of the $1,000,000 gross. A two-dollar difference in the wrong direction, but it is the line the marks are on. Any one-off Budget reduction would come off at the end; none is assumed here.

Salaries Tax rules → · more worked illustrations →

3. Profits Tax IRO ss.14–19C — textbook Ch.20

Start from profit per the accounts — never rebuild from gross profit The textbook sets this out as an explicit WRONG vs CORRECT contrast, and it is worth the space. A profits tax computation is an adjustment of the accounting profit, not a fresh income statement.

✗ Wrong — the gross profits method

Gross profitX
Add: assessable incomeX
Less: allowable expenses under the IRO(X)
Less: depreciation allowances(X)
Less: charitable donation(X)
Assessable profitX

Rebuilding the whole profit from scratch. It loses the audit trail back to the accounts, and any expense you forget to re-add is silently allowed.

✓ Correct — adjust the accounting profit

Profit / (loss) per the accountsX
Add: non-allowable expenses chargedX
Less: non-assessable income credited, and deductible amounts not in the accounts(X)
Less: depreciation allowances(X)
Less: charitable donation (capped)(X)
Assessable profitX

Every line is a reconciling difference an assessor can trace to the accounts. This is the format to use.

Profits Tax Computation · Year of Assessment 20XX/XX · basis period ______
Profit / (loss) per the accountsX
Add: non-allowable expenses
Charitable donation (added back here, relieved later)X
Depreciation per the accountsX
Expenses attributable to offshore profitsX
Fines and penaltiesX
General provision for doubtful debtsX
Improvements (capital)X
Initial purchase of carpets, curtains and similarX
Interest failing ss.16(2), (2A)–(2CC)X
Legal fees of a capital natureX
Profits tax and property tax charged in the accountsX
Salaries paid to the proprietor or partnersX
Share of joint venture loss per the accountsX
Retirement scheme contributions above the allowable proportionX
X
Less: non-assessable income, and deductions not in the accounts
Dividends(X)
Interest exempt from profits tax(X)
Offshore interest and offshore profits(X)
Prescribed fixed assets (100% deduction)(X)
Recovery of bad debts not previously allowed(X)
Share of joint venture profit per the accounts(X)
X
Less: depreciation allowances
Plant and machinery(X)
Industrial building allowance(X)
Commercial building allowance(X)
Subtotal — call this YY
Less: charitable donation, restricted to 35% of Y(Z)
Assessable profitP
Less: loss brought forward(X)
Less: loss set off under s.19C(5)(X)
Net assessable profitN
Profits tax: two-tiered rates on N — corporations 8.25% on the first $2,000,000 and 16.5% on the remainder; unincorporated 7.5% / 15%T
Less: provisional profits tax paid(X)
Less: property tax set off under s.25(X)
Profits tax liabilityR
Three ordering traps in this format 1. The charitable donation is added back first and relieved last, because its 35% cap is measured on Y — after depreciation allowances. Deducting it early gives the wrong cap.
2. Depreciation allowances come off before the donation, never after.
3. Only one entity in a group may claim the two-tiered first-tier rate in a year. Where the question mentions connected entities, say which one is nominated.
Worked example Built on the textbook's Ch.20 format, current rates

A Hong Kong company's accounts show a profit of $2,500,000. Charged in arriving at it: depreciation $300,000, a charitable donation $80,000, a fine $20,000, and a general provision for doubtful debts $50,000. Credited to it: dividend income $100,000 and offshore trading profit $200,000. Depreciation allowances for the year are $260,000, and there is a loss brought forward of $310,000. It is the nominated group entity for the two-tiered rate.

Profits Tax Computation · Year of Assessment 2026/27
Profit per the accounts2,500,000
Add: depreciation300,000
Add: charitable donation80,000
Add: fine20,000
Add: general provision for doubtful debts50,000
2,950,000
Less: dividend income(100,000)
Less: offshore profit(200,000)
2,650,000
Less: depreciation allowances(260,000)
Y2,390,000
Less: charitable donation — 35% of Y is 836,500, so the full $80,000 is allowed(80,000)
Assessable profit2,310,000
Less: loss brought forward(310,000)
Net assessable profit2,000,000
Profits tax: $2,000,000 × 8.25% (all within the first tier)165,000

Watch the donation: added back at $80,000 and then allowed at $80,000 — it looks like a wasted round trip, and it is, until the 35% cap bites. Had Y been $200,000, the cap would be $70,000 and only that much would come back. The round trip is what makes the cap computable.

Profits Tax rules → · more worked illustrations → · how this maps to BIR51 →

4. Depreciation allowances — plant and machinery IRO Part 6 — textbook Ch.31

Plant and machinery is grouped into three pools by annual allowance rate — 10%, 20% and 30%. The schedule below is the standard layout; with it memorised the work becomes filling in blanks.

Depreciation Allowance Schedule · Year of Assessment 20XX/XX
10%20%30%Allowances
Written down value b/fXXX
Additions (qualifying cash purchases)XXX
Less: initial allowance, 60% of the addition(X)(X)(X)X
XXX
Less: disposal proceeds (limited to original cost)(X)(X)(X)
Reduced valueXXX
Less: annual allowance at the pool rate(X)(X)(X)X
Written down value c/fXXX
Total depreciation allowancesX
PointDetail
Initial allowance, 60%On the addition, not on the pool. Taken before the annual allowance, so the annual allowance is computed on the reduced figure.
Order: IA → disposal → AADisposals come out after the initial allowance and before the annual allowance. Reversing this changes every figure below it.
Four kinds of additionCash purchase — pooled, 60% IA on the cash price. Hire purchase — not pooled; 60% IA only on the capital portion of the deposit and instalments paid in the year. Private asset introduced into the business — pooled, but no initial allowance. Asset used partly privately — not pooled; dealt with separately and apportioned.
Balancing adjustmentArises only when the pool is emptied — proceeds exceeding the pool give a balancing charge; a residue with no assets left gives a balancing allowance. A disposal from a continuing pool creates neither.
Prescribed fixed assets100% deduction under s.16G — these never enter the pool at all. They belong in the profits tax computation, not here.
Worked example Built on the textbook's Ch.31 schedule

Pools brought forward: 10% $100,000, 20% $200,000, 30% $300,000. During the year the business bought machinery for cash $150,000 (a 20% pool item) and sold an item from the 30% pool for $50,000, below its original cost.

10%20%30%Allowances
Written down value b/f100,000200,000300,000
Additions—150,000—
Less: initial allowance (60% × 150,000)—(90,000)—90,000
100,000260,000300,000
Less: disposal proceeds——(50,000)
Reduced value100,000260,000250,000
Less: annual allowance(10,000)(52,000)(75,000)137,000
Written down value c/f90,000208,000175,000
Total depreciation allowances227,000

The 20% pool's annual allowance is $52,000, not $70,000 — 20% of $260,000 after the initial allowance, not of the $350,000 before it. The $227,000 total is the single figure that carries into the profits tax computation above.

Depreciation & Allowances rules → · more worked illustrations →

5. Personal Assessment IRO ss.40–43

The one format that consumes the other four: it takes the net assessable value from the property computation, the net assessable income from the salaries computation and the net assessable profit from the profits computation, and re-taxes the lot at progressive rates.

Personal Assessment Computation · Year of Assessment 20XX/XX
Net assessable value — from the property tax computationX
Net assessable income — from the salaries tax computationX
Net assessable profit — sole proprietorships and share of partnershipsX
Total incomeX
Less: interest on money borrowed to produce property income (capped at that property's NAV)(X)
Less: concessionary deductions(X)
Less: business loss of the year(X)
Less: loss brought forward under Personal Assessment(X)
Reduced total incomeRTI
Less: personal allowances(X)
Net chargeable incomeNCI
(b) Progressive rates on NCIb
(c) Standard rate on RTI — before allowancesc
Tax payable — the lower of (b) and (c)X
Joint election — apportioning the tax Where a married couple elects jointly, the allowances come off the joint reduced total income and the tax is computed once, then split in the ratio of each spouse's reduced total income — not gross. Each receives their own notice of assessment.

Four full worked examples, including one where electing costs money, are on the Personal Assessment page →

What has changed since the textbook

The 22nd edition states the law to 31 May 2024. Every rate and figure in the formats above was re-checked against IRD. Here is what moved and what did not, so you can see that the unchanged items were checked rather than assumed.

ItemTextbook (to 31 May 2024)Current — used above
Salaries tax standard rate Flat 15% on net income (Ch.12 format, line c) changed Two-tiered from YA 2024/25: 15% on the first $5,000,000, 16% on the remainder
Personal allowances Basic $132,000 / married $264,000 / child $130,000 era changed From YA 2026/27: basic $145,000, married $290,000, child $140,000, single parent $145,000, dependent parent 60+ $55,000 (IRD pam61e)
One-off tax reduction Table runs to 2023/24, ceiling $3,000 changed A 100% reduction capped at $3,000 also applied for 2025/26. Check the current Budget — none is assumed in the examples above
Child allowance, newborns Not in this edition proposed 2026 Policy Address: $160,000 for a 2nd or subsequent child born on/after 16 Sep 2026 — needs an amendment ordinance, so not used above. details →
Property tax standard rate15%unchanged 15%
20% statutory repair allowance20% of AV after ratesunchanged
Two-tiered profits tax rates8.25% / 16.5% and 7.5% / 15%, first $2,000,000unchanged
Salaries tax progressive bands2/6/10/14% on four $50,000 bands, then 17%unchanged
Initial allowance on P&M60%unchanged
Annual allowance pools10% / 20% / 30%unchanged
Donations cap35%unchanged
Rental value percentages10% / 8% / 4%unchanged
Not reflected in the textbook's chapters at all The 22nd edition predates the 2026 stamp duty amendments, the 2026 bills on funds/FIHV/carried interest and on shipping and commodity trading, the CARF and amended-CRS legislation, and the September 2026 Policy Address measures. None of those change the five computation formats above, but they do change the surrounding rules — see IRD What's New.

Source documents

  • Hong Kong Taxation and Tax Planning, 22nd ed. (Ho & Mak, Pilot Publishing, June 2024) — Ch.7 pp.99–101, Ch.12 pp.212–213, Ch.20 pp.417–418, Ch.31 p.599law to 31 May 2024
  • IRD — Allowances, Deductions and Tax Rate Table (pam61e): the 2026/27 allowance and rate figuresread 24 Sep 2026
  • IRD — A Brief Guide to Personal Assessment (pam37e)read 24 Sep 2026
  • IRD — What's New, for changes after the textbook's cut-offread 24 Sep 2026
How the textbook was read The 22nd edition is a scanned PDF with no text layer, and no OCR is available in this environment. The pages above were located through the book's own index and read by rendering each page as an image. Layouts are reproduced as structure — line order, subtotal names and captions — not as copied text, and every figure in the worked examples was recomputed independently. The one example carried over directly (Mr Gap) is labelled as the textbook's own.
Exam technique — the most heavily weighted question type

Tax Reconciliation

"Here is a computation prepared by someone who got it wrong. Here are ten notes. Produce the revised computation." How to attack it, and how to prove your answer with a reconciliation.

稅務調節考試最常見的題型:給一份錯誤的利得稅或個人入息課稅計算表及十項附註,要求重新編製。兩條完整例題,逐項分析、修正後計算表及完全吐合的調節表。

1. The question type, and what it is really testing

You are given a profits tax or personal assessment computation prepared by a bookkeeper, a client, or "the previous accountant". It is internally consistent — the arithmetic adds up — but several treatments are wrong. A set of numbered notes gives you the facts. You must produce the corrected computation.

It is not a computation question. It is a review question. A blank-page computation tests whether you can build a format. This tests something harder: whether you can look at a plausible-looking answer and find what is wrong with it. That is what tax work actually is — almost nothing arrives as a blank page, and the figure in front of you always looks reasonable.

Three consequences follow, and they drive everything on this page:

Because……therefore
The given computation looks plausibleYou cannot spot errors by eye. You must work note by note, in order, and decide an adjustment for each — including "no adjustment".
Some notes are distractorsA note that needs no adjustment still earns a mark if you say so and why. Silence earns nothing and looks like an oversight.
Errors can offset each otherThe bottom line can look close to right while several treatments are wrong. Never sanity-check by the final figure. Illustration A below is built to show this happening.

2. The six-step method

StepDo this
1Do not edit the given computation. Start a clean one from profit per the accounts (or, for personal assessment, from each source's own correct figure). Editing someone else's layout inherits their structural errors.
2Rule up a note-by-note working schedule before touching the computation: note number, treatment, adjustment, amount. Every note gets a row, including the ones needing no adjustment.
3Decide each note in isolation. Is the item chargeable / deductible? Was it already in the accounts? Those two questions together give the adjustment — an item can be deductible and still need no adjustment because it was already correctly charged.
4Build the revised computation in the standard format, feeding in the schedule's figures. Keep the donation add-back-then-relieve round trip, and keep depreciation allowances before the donation.
5Reconcile from the given figure to yours, line by line. This is the step candidates skip, and it is where the marks and the self-check both live.
6Reconcile the tax too, not just the profit. Rate errors, set-offs and reliefs live below the net assessable profit line and are easy to leave uncorrected.
Why step 5 is worth the minutes it costs The reconciliation is self-marking. If it does not arrive at your revised figure, you have made an error somewhere and you still have time to find it. If it does arrive, you have proved your answer and shown the examiner your reasoning in one compact table. It is the cheapest insurance in the paper.

3. Illustration A — Profits tax: the question

Question

Kingsway Trading Limited carries on a trading business in Hong Kong and prepares accounts to 31 December. The profit per the audited accounts for the year ended 31 December 2026 was $3,200,000.

The company's bookkeeper prepared the following profits tax computation for the year of assessment 2026/27.

REQUIRED: Using the notes below, prepare a revised profits tax computation for the year of assessment 2026/27, and reconcile the revised net assessable profit to the figure computed by the bookkeeper.

✗ As prepared by the bookkeeper — Kingsway Trading Limited, YA 2026/27
Profit per accounts3,200,000
Add: depreciation420,000
3,620,000
Less: dividend income(150,000)
Less: charitable donations(250,000)
Less: depreciation allowances(380,000)
Assessable profit2,840,000
Less: loss brought forward(240,000)
Net assessable profit2,600,000
Profits tax at 8.25%214,500
Notes
NoteInformation
1The profit is after charging depreciation of $420,000. Depreciation allowances properly computed under Part 6 of the IRO for the year amount to $505,000.
2Turnover includes $680,000 of profit on a contract negotiated and concluded entirely in Singapore by the company's Singapore branch. The Assessor has accepted this profit as offshore.
3Other income includes dividends of $150,000 from a company listed in Hong Kong.
4Other income includes $90,000 of interest on a Hong Kong dollar deposit with a licensed bank in Hong Kong.
5Administrative expenses include a fine of $35,000 imposed for a breach of licensing conditions.
6Administrative expenses include an increase in the general provision for doubtful debts of $60,000, and a specific bad debt written off of $45,000 in respect of a trade debtor who has been wound up.
7Charitable donations of $250,000 to approved charitable institutions were charged in arriving at the profit per the accounts.
8Finance costs include $120,000 of interest paid to a director on a loan to the company. The director is not chargeable to profits tax on that interest, so the conditions in s.16(2) are not satisfied.
9The company owns an office in Hong Kong which it lets to a tenant. The rental income is included in the profit per the accounts. Property tax of $48,000 for the year was paid and charged in the accounts.
10The agreed loss brought forward from the year of assessment 2025/26 is $240,000. Kingsway Trading Limited is the only Hong Kong entity in its group and is entitled to the two-tiered profits tax rates.

4. Illustration A — note-by-note working

Build this before the computation. Two questions per note: is the item chargeable or deductible? and how was it treated in the accounts? The adjustment is the difference between the two.

NoteCorrect treatmentAdjustment$
1 Accounting depreciation is not deductible; statutory depreciation allowances replace it. Add back $420,000; deduct the correct allowances of $505,000, not the bookkeeper's $380,000. Add / Deduct420,000
(505,000)
2 Offshore profit is outside the s.14 charge. The bookkeeper missed it entirely — the largest single error. Deduct(680,000)
3 Dividends from a Hong Kong company are not chargeable (s.26). Correctly deducted by the bookkeeper. Deduct(150,000)
4 Interest on a HKD deposit with a licensed bank is exempt under the Exemption from Profits Tax (Interest Income) Order. Missed. Deduct(90,000)
5 A fine is not incurred in the production of profits and is not deductible. Missed. Add back35,000
6 General provision is not deductible (s.16(1)(d)) — add back $60,000. The specific write-off of a debt of a wound-up debtor is deductible and was correctly charged — no adjustment. Add back
no adj.
60,000
—
7 Add back the $250,000 charged, then relieve it under s.16D restricted to 35% of the profit after depreciation allowances. The bookkeeper simply deducted it a second time. Add back
then relieve
250,000
(250,000)
8 Interest failing s.16(2) is not deductible. Missed. Add back120,000
9 Two separate points. Property tax charged in the accounts is not deductible — add back $48,000. Separately, it is set off against the profits tax payable under s.25, below the tax line. Both were missed. Add back
and set off
48,000
(48,000)
10 Loss brought forward is set off after the donation. The two-tiered rates apply, so 8.25% on the first $2,000,000 and 16.5% on the remainder — not 8.25% on the whole. Deduct / rate(240,000)
Note 6 is the distractor, and Note 9 is the double-barrelled one Note 6 gives you two figures where only one moves — say explicitly that the specific write-off needs no adjustment. Note 9 carries two marks in two different places: an add-back in the computation and a set-off under the tax. Answering only the add-back loses half of it.

5. Illustration A — the revised computation

✓ Kingsway Trading Limited — Profits Tax Computation, YA 2026/27 (basis period: year ended 31 December 2026)
Profit per accounts3,200,000
Add: non-allowable items
Depreciation (1)420,000
Charitable donations (7)250,000
Fine (5)35,000
General provision for doubtful debts (6)60,000
Interest failing s.16(2) (8)120,000
Property tax charged (9)48,000
4,133,000
Less: non-assessable income
Offshore profit (2)(680,000)
Dividend income (3)(150,000)
Exempt bank deposit interest (4)(90,000)
3,213,000
Less: depreciation allowances (1)(505,000)
Profit before charitable donations (Y)2,708,000
Less: approved charitable donations (7)
lower of $250,000 actual and 35% × $2,708,000 = $947,800
(250,000)
Assessable profit2,458,000
Less: loss brought forward (10)(240,000)
Net assessable profit2,218,000
Tax payable
First $2,000,000 at 8.25% (10)165,000
Remaining $218,000 at 16.5%35,970
Profits tax200,970
Less: property tax set off under s.25 (9)(48,000)
Profits tax liability152,970

No one-off Budget reduction is assumed. If the year's Budget grants one, it comes off at the very end, after the s.25 set-off.

6. Illustration A — the reconciliation

This is the part the question specifically asked for, and the part most candidates omit. It starts at the bookkeeper's figure and arrives at yours.

Reconciliation of net assessable profit
Net assessable profit per the bookkeeper's computation2,600,000
Offshore profit not excluded (2)(680,000)
Exempt bank deposit interest not excluded (4)(90,000)
Fine not added back (5)35,000
General provision not added back (6)60,000
Interest failing s.16(2) not added back (8)120,000
Property tax charged not added back (9)48,000
Donations deducted without being added back (7)250,000
Additional depreciation allowances ($505,000 − $380,000) (1)(125,000)
Revised net assessable profit2,218,000
Reconciliation of tax
Profits tax per the bookkeeper's computation214,500
Effect of the reduction in net assessable profit, at the rates properly applicable(13,530)
Revised profits tax200,970
Property tax set off under s.25, omitted (9)(48,000)
Revised profits tax liability152,970
The point of this illustration: two errors pulling in opposite directions The bookkeeper overstated the profit by $382,000 ($2,600,000 against $2,218,000) — which pushes tax up. But they also applied 8.25% to the whole profit instead of tiering at $2,000,000 — which pulls tax down. On the correct profit of $2,218,000, a flat 8.25% would have given $182,985 against the true $200,970, understating tax by $17,985.

The two errors partly cancel. That is exactly why the bottom line tells you nothing about whether a computation is right, and why the note-by-note schedule is not optional.

7. Illustration B — Personal assessment

Question

Mr and Mrs Lam have elected jointly for personal assessment for the year of assessment 2026/27. Mr Lam's net assessable income from employment is $600,000. Mrs Lam runs a sole proprietorship whose assessable profit is $180,000, and owns a Hong Kong flat let at $30,000 a month throughout the year. She paid rates of $12,000 and mortgage interest of $200,000 on that flat. Neither has any other income, deduction or dependant.

A friend prepared the computation below. REQUIRED: prepare the revised computation, show the apportionment between the spouses, and reconcile to the friend's figure.

✗ As prepared by a friend — Mr & Mrs Lam, YA 2026/27
Mr Lam — salary600,000
Mrs Lam — business profit180,000
Mrs Lam — rental income ($30,000 × 12)360,000
Total income1,140,000
Less: mortgage interest(200,000)
Less: rates paid(12,000)
Reduced total income928,000
Less: basic allowance D26 exam (YA 2025/26): $132,000(145,000)
Net chargeable income783,000
Tax at progressive rates115,110
ErrorWhat is wrong
1Property brought in at gross rent. Personal assessment takes the net assessable value: rates are deducted inside the property computation, and the 20% statutory allowance is then taken. Deducting rates as a separate line below total income skips the 20% entirely.
2A basic allowance claimed where a jointly electing married couple is entitled to the married person's allowance of $290,000.
3No standard-rate comparison. Tax under personal assessment is the lower of progressive rates on net chargeable income and the standard rate on reduced total income.
4No apportionment between the spouses. On a joint election each receives their own assessment for their share.
✓ Mr & Mrs Lam — Personal Assessment Computation, YA 2026/27
Mr Lam — net assessable income600,000
Mrs Lam — net assessable profit180,000
Mrs Lam — net assessable value:
Rent ($30,000 × 12)360,000
Less: rates paid by owner(12,000)
Less: 20% statutory allowance ($348,000 × 20%)(69,600)
Net assessable value278,400
Total income1,058,400
Less: interest to produce property income
$200,000, within the $278,400 NAV cap, so allowed in full
(200,000)
Reduced total income858,400
Less: married person's allowance D26 exam (YA 2025/26): $264,000(290,000)
Net chargeable income568,400
(b) Progressive: 1,000 + 3,000 + 5,000 + 7,000 + ($368,400 × 17%)78,628
(c) Standard rate: $858,400 × 15%128,760
Tax payable — the lower78,628
Apportionment — in the ratio of each spouse's reduced total income
Mr Lam: $78,628 × 600,000 / 858,40054,959
Mrs Lam: $78,628 × 258,400 / 858,400
her share is $180,000 + $278,400 − $200,000 = $258,400
23,669
Total78,628
Reconciliation
Net chargeable income per the friend's computation783,000
Property taken at gross rent instead of net assessable value (1)(81,600)
Rates wrongly deducted a second time, below total income (1)12,000
Married person's allowance in place of basic allowance (2)(145,000)
Revised net chargeable income568,400
Tax: $115,110 per the friend, against $78,628 revised — overstated by $36,482.
Note how the rates error works The friend deducted rates of $12,000 — and got a worse answer than ignoring them, because deducting them in the wrong place forfeited the 20% statutory allowance of $69,600. Doing something reasonable in the wrong line of a computation is not half right; it is wrong, and here it is wrong by $57,600.

8. The errors examiners plant, in rough order of frequency

Planted errorHow to catch it
Offshore profit left inAny note mentioning a place outside Hong Kong is a source question. Decide it explicitly.
Donation deducted without being added backIf it was charged in the accounts it must go back in first, or the 35% cap cannot be computed.
Donation cap on the wrong base35% of profit after depreciation allowances, not of profit per accounts.
Accounting depreciation left in, or DA figure wrongAdd back the accounts figure and deduct the Part 6 figure. They are never the same number.
General vs specific provisionGeneral is added back, specific is not. The question will give you both.
Flat rate instead of two-tieredCheck the rate line every time, and check whether the entity is the nominated group member.
Property tax: add-back or set-off missedIt is two adjustments in two places, from one note.
Interest failing s.16(2)Any interest paid to a director, shareholder or associate is a s.16(2) question.
Exempt bank interest left inHKD deposit interest from a licensed bank is exempt.
Loss brought forward in the wrong placeAfter the donation, not before.
Personal assessment: gross rent not NAVProperty always enters at net assessable value.
Personal assessment: standard-rate comparison omittedAnd when performed, on reduced total income — before allowances.
Wrong allowance for a married coupleJoint election takes the married person's allowance.

9. Marking technique

Earns marks

  • A note number against every line of the revised computation — the marker can follow your reasoning without hunting.
  • Saying "no adjustment" for a distractor, with one clause of reason.
  • Showing the cap working even when the cap does not bite: "lower of $250,000 and 35% × $2,708,000 = $947,800".
  • The reconciliation, even a rough one.
  • Correct subtotal names: assessable profit, net assessable profit, reduced total income, net chargeable income.
  • A one-line heading: taxpayer, tax, year of assessment, basis period.

Loses marks

  • Editing the given computation instead of starting clean — you inherit its structure and its errors.
  • Silence on a distractor note. Indistinguishable from missing it.
  • Netting several adjustments into one unexplained figure.
  • Stopping at net assessable profit when the question asked for the liability — rate, set-offs and reliefs are marks.
  • Checking your work against the bottom line. Offsetting errors make a wrong answer look right.
  • Correct treatment written in the wrong line, as with the rates in Illustration B.
If you run short of time Produce the note-by-note schedule and stop. It carries most of the technical marks, since it shows the decision on every item. A beautifully formatted computation with three treatments wrong scores less than a rough schedule that gets all ten notes right.

The underlying formats → · Profits Tax rules → · Personal Assessment rules → · more practice questions →

10. Source documents

  • Both illustrations are original — written for this Hub in the standard exam format, not reproduced from any paper or textbook24 Sep 2026
  • Formats follow Hong Kong Taxation and Tax Planning (22nd ed.) Ch.20 and IRD's Personal Assessment guide — see Computation Formats—
  • Rates and allowances: IRD Allowances, Deductions and Tax Rate Table (pam61e), YA 2026/27read 24 Sep 2026
Every figure was computed, not estimated Both illustrations were built arithmetically so that the reconciliations close exactly: Illustration A's eight adjustments take $2,600,000 to $2,218,000, and Illustration B's three take $783,000 to $568,400. If you work them yourself and land elsewhere, the error is worth finding — that is the point of the exercise.
Application tool

Transaction Checker

Search a transaction or item by keyword to see whether it is Taxable / Non-taxable / Deductible / Non-deductible / Dutiable, with the exact IRO/SDO section and a link to the full explanation. This is the working tool for tax computation analysis — the topic pages hold the underlying study material.

交易稅務檢查器按交易或會計項目快速查看可能屬於應課稅、非應課稅、可扣稅、不可扣稅或須繳印花稅,並連回相關章節。
How to use Type a keyword describing the transaction (e.g. "lease premium", "director fee", "bad debt", "management fee", "donation", "share transfer"). Narrow further with the Tax Type or Status dropdowns. This list is curated from the topic pages — if a transaction isn't here, check the relevant topic page directly, or ask Claude to add it.

StatusTax TypeTransaction / ItemSectionNote
Scope & limits This tool covers the core items documented across the five topic pages — it is a lookup aid, not a substitute for professional judgement. Real transactions often combine several of these characterisations (e.g. a lease premium touches both Profits Tax and Property Tax) or turn on facts not captured in a one-line description (e.g. badges-of-trade analysis for a "capital vs revenue" asset sale). Always read the full topic-page section and the underlying DIPN/IRO text linked from it before finalising a position.
Catalogue

DIPN Index

Every currently-in-force IRD Departmental Interpretation & Practice Note (DIPN), Stamp Office Interpretation & Practice Note (SOIPN), and Estate Duty Office note (EDOIPN) — 73 documents total. Items backing one of the five core study pages are marked accordingly; the rest are reference-only with a short summary.

DIPN 索引列出 IRD DIPN、SOIPN 及 EDOIPN 文件,方便按編號、主題或關鍵字搜尋,每行並連結至稅務局官方 PDF。
Where the documents come from This is a catalogue, not an archive. Every row's Official column links to IRD's own PDF on ird.gov.hk, which is always the current version — a copy saved here would go stale the moment IRD revises it. The titles, dates and summaries below are this Hub's own index over those documents; the documents themselves remain IRD's.

No.TitleGroupDateSummaryOfficialStatus
Scope note Per the agreed build scope: DIPNs tied to the five core taxes (Profits, Property, Salaries, Stamp Duty, Depreciation & Allowances) are fully reflected in their topic pages, with worked illustrations. Everything else here — transfer pricing, aircraft/ship leasing, corporate treasury, offshore funds, cross-border DTAs, field audit, advance rulings, estate duty — is downloaded and briefly summarized for reference, but does not yet have a dedicated study page. Ask Claude to build one out if your team needs deeper coverage of a specific reference-only topic.
Business — Profits Tax

Profits Tax

Inland Revenue Ordinance (Cap. 112), Part 4 — charged on assessable profits arising in or derived from Hong Kong from a trade, profession or business carried on in Hong Kong.

利得稅涵蓋香港來源原則、兩級制稅率、應課稅收入、扣稅開支、虧損、FSIE、Patent Box 及基本計算格式。

1. Overview & Charging Basis IRO s.14

Hong Kong taxes profits on a territorial source basis, not on residence. Section 14(1) charges profits tax on every person (including a corporation) carrying on a trade, profession or business in Hong Kong, on assessable profits arising in or derived from Hong Kong for that trade/profession/business — profits from the sale of capital assets are expressly excluded from the charge.

Statutory text — s.14(1) "...profits tax shall be charged for each year of assessment on every person carrying on a trade, profession or business in Hong Kong in respect of his assessable profits arising in or derived from Hong Kong for that year from such trade, profession or business (excluding profits arising from the sale of capital assets) as ascertained in accordance with this Part."

Three conditions must all be met for a charge to arise: (1) the person carries on a trade, profession or business in Hong Kong; (2) the trade/profession/business produces profits other than from the sale of capital assets; (3) the profits are sourced in Hong Kong. Locality of profits is a question of fact determined by what the taxpayer did to earn the profit and where — see DIPN 21 (Locality of Profits) for the "broad guiding principle" drawn from Hang Seng Bank, HK-TVB International, Kwong Mile, and other leading cases.

2. Rates & Recent Changes Schedule 8B

Two-tiered profits tax rates (from YA 2018/19, current)
Taxpayer typeFirst HKD 2,000,000 of assessable profitsRemainder
Corporations8.25%16.5%
Unincorporated businesses (sole proprietors / partnerships)7.5%15%

Legislated via s.14(2)/(3) referring out to Schedule 8B (two-tiered rates) — Schedule 8 sets the flat standard/corporate rate that continues to apply where a group of connected entities has more than one entity in Hong Kong (only one connected entity per group may be nominated each year to access the discounted first-tier rate; s.14AAC deals with connected entities generally).

Recent changes to watch
  • Refined FSIE regime — effective 1 January 2023 (Division 3A of Part 4, added by 17 of 2022) — see §6 below.
  • Patent Box concession — 5% concessionary rate on qualifying IP income from YA 2023/24 (Inland Revenue (Amendment) (Tax Concessions for Intellectual Property Income) Ordinance 2023).
  • Pillar Two — Income Inclusion Rule + Hong Kong Minimum Top-up Tax for in-scope MNE groups, effective for fiscal years beginning on/after 1 January 2025.
  • One-off relief — Inland Revenue (Amendment) Ordinance 2026 (gazetted 22 May 2026): 100% profits tax reduction for YA 2025/26, capped at HKD 3,000 per taxpayer. (Source: PwC Tax Summaries, reviewed 22 Jul 2026 — verify against the gazetted ordinance before relying on this for a filing.)
Bills in progress — not yet law (as at 24 September 2026)
  • Funds / FIHV / carried interest — Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026, gazetted 12 June 2026, first reading 24 June 2026. Widens the definition of "fund", broadens the schedule of qualifying assets (notably to support private credit), removes the 5% cap on incidental transactions, relaxes the exemption conditions for special purpose entities and family-owned SPEs, and enhances the carried interest regime — but adds a tax reporting mechanism and economic substance requirements modelled on the FIHV regime. (Gazettal press release, 12 Jun 2026; FSTB response on carried interest, 12 Aug 2026.)
  • Shipping & physical commodity trading — Inland Revenue (Amendment) (Tax Concessions for Shipping-related Activities and Physical Commodity Trading) Bill 2026, gazetted 12 June 2026. Offers shipping-related companies an elective 15% concessionary rate (elected annually) as a BEPS 2.0-aware alternative to the existing 0%/8.25% concessions, and creates a new half-rate (8.25%) concession for physical commodity trading. (Press release, 10 Jun 2026.)
  • Corporate treasury centres — the Government published an Action Plan to Promote Development of Corporate Treasury Centres (9 Jun 2026) and launched a consultation on enhancing the CTC tax concession regime (27 Jul 2026). Expect the qualifying-activity and safe-harbour conditions for the 8.25% CTC rate to change — check before advising a group treasury structure.
  • Qualifying debt instruments — the list of debt instruments and sovereign bonds eligible for profits tax concession or exemption was refreshed on 30 June 2026. The list is the operative test — do not rely on an older copy.
  • Pillar Two filing — IRD published the GIR XML schema and user guides for the GloBE Information Return on 8 June 2026. In-scope MNE groups now have the machine-readable filing format. (IRD BEPS 2.0 page.)

3. Taxable / Non-Taxable Receipts IRO s.15

Section 15(1) deems certain sums to be Hong Kong-source trading receipts even though they might not otherwise be so regarded — this closes gaps the general s.14 source test would otherwise leave open (e.g. royalties, hire charges). Combine this with the general case-law source principle (DIPN 21) and the FSIE deeming rule (§6) to classify any receipt.

StatusReceiptBasis
TaxableRoyalties / sums for the use of, or right to use in Hong Kong, any patent, trade mark, copyright, design, secret process/formula or similar IPs.15(1)(b)
TaxableSums for use outside Hong Kong of IP where the payer claimed a Hong Kong deduction for the payments.15(1)(ba)
TaxableGrants, subsidies or similar financial assistance connected with carrying on the HK trade/business (other than towards capital expenditure)s.15(1)(c)
TaxableHire, rental or similar charges for use of movable property in Hong Kongs.15(1)(d)
TaxableInterest derived from Hong Kong received by a corporation carrying on a HK trade/businesss.15(1)(f)
TaxableSums from exhibition/use in HK of film, tape, sound recording or related advertising materials.15(1)(a)
Non-taxableProfits from the sale of capital assetss.14(1) (excluded from the charge)
Non-taxableInterest on a Hong Kong bank deposit earned by a person other than a financial institutionExemption from Profits Tax (Interest Income) Order 1998 — see DIPN 34; lost if the deposit secures a loan whose interest is tax-deductible (no partial exemption)
Non-taxableSpecified foreign-sourced income that satisfies the FSIE economic substance / nexus / participation conditionsDivision 3A, Part 4 (s.15H onward) — see §6
Taxable (deemed)Specified foreign-sourced income (interest, dividends, IP income, disposal gains on equity interests) that fails the FSIE conditionss.15I — deemed to arise in/derive from Hong Kong

4. Deductible / Non-Deductible Expenses IRO ss.16–17

The general test (s.16(1)) is that outgoings and expenses are deductible to the extent incurred in the basis period in the production of chargeable profits (the "Ronpibon Tin" apportionment principle — see DIPN 3 for apportioning mixed-purpose expenses). Section 17 then carves out specific exclusions even where the general test would otherwise be met.

StatusItemBasis / conditions
DeductibleInterest on money borrowed for producing chargeable profits, plus related legal/procuration fees and stamp dutys.16(1)(a), subject to the anti-avoidance conditions in s.16(2)–(2C) (see DIPN 13A)
DeductibleRent paid for land/buildings used to produce chargeable profits (capped at assessable value if paid to a related party)s.16(1)(b)
DeductibleForeign tax of substantially the same nature as HK tax, paid on income also chargeable under s.15(1)(f)/(g)/(i)–(lb)s.16(1)(c)/(ca), restricted by s.16(2J) where a DTA already gives s.50 credit relief (see DIPN 28)
DeductibleBad debts written off, and doubtful debts to the extent estimated bad, if previously included as a trading receipts.16(1)(d)
DeductibleR&D expenditure — 100% for Type A, enhanced 300%/200% for Type B (see §4A)s.16B
DeductibleCapital expenditure on patents / know-how rights (one-off, no spreading)s.16E — see DIPN 49
DeductibleCapital expenditure on "Specified IP Rights" (copyright, registered trade marks/designs, plant variety rights) — spread over 5 yearsss.16EA–16EC — see DIPN 49
DeductibleCapital expenditure on "prescribed fixed assets" (manufacturing plant, computer hardware/software) — 100% one-offs.16G — see DIPN 5
Non-deductibleDomestic or private expenses (incl. home-to-office travel; MPF contributions in the person's own capacity as scheme member)s.17(1)(a)
Non-deductibleAny disbursement or expense not incurred for the purpose of producing the chargeable profitss.17(1)(b)
Non-deductibleCapital expenditure, or any loss or withdrawal of capitals.17(1)(c)
Non-deductibleCost of improvements (as opposed to repairs)s.17(1)(d)
Non-deductibleSums recoverable under insurance or an indemnity contracts.17(1)(e)
Non-deductibleRent/expenses for premises not occupied or used to produce the chargeable profitss.17(1)(f)
Non-deductibleTax paid under the IRO itself (property tax not set off, profits tax) — except salaries tax paid on employees' remunerations.17(1)(g)
Non-deductibleEmployer retirement-scheme contributions (ORSO/MPF) in excess of 15% of the employee's total emoluments for the periods.17(1)(h)/(i)
Non-deductibleManagement fee paid to a related "Type II" service company in excess of cost plus a 12.5% mark-upDIPN 24 minimum-requirements test (administrative practice, not a numbered section)

4A. Research and Development — the enhanced deduction IRO s.16B, Schedule 45

Qualifying R&D expenditure splits into two types with very different treatment. Getting the split wrong, or applying the enhanced rate to the whole of Type B, is the error the June 2026 examining team reported on the question fewest candidates answered correctly.

TypeWhat falls in itDeduction
Type A Qualifying R&D expenditure that is not Type B — including plant and machinery bought for R&D, fees paid to an outside expert or consultant, and testing fees 100% — a normal full deduction, no uplift
Type B Staffing costs of employees directly and actively engaged in qualifying R&D, and consumable items used up in it. Also payments to a designated local research institution. 300% on the first $2,000,000, then 200% on the remainder — no cap on the 200% tier
Three ways to get this wrong 1. Applying 300% to all Type B expenditure instead of only the first $2,000,000.
2. Treating everything as Type B — plant and machinery, consultancy fees and testing fees are Type A and get 100% only.
3. Leaving plant and machinery out altogether because it is capital. Under s.16B it is deductible at 100%; it does not go into the depreciation allowance pools.
Worked example Original; mechanics verified against the June 2026 examiner's report worked answer

Delta Ltd incurred the following on qualifying R&D in the year: plant and machinery $0.6m, a consultancy fee to an independent expert $0.4m, staffing costs of the research team $1.5m, and consumable items $0.9m.

Type A — plant and machinery $0.6m + consultancy $0.4m = $1.0m, at 100%1.0m
Type B — staffing $1.5m + consumables $0.9m = $2.4m
First $2.0m at 300%6.0m
Remaining $0.4m at 200%0.8m
Total deduction7.8m

$3.4m was actually spent and $7.8m is deducted. Common wrong answers on these facts: $8.2m (300% on all $2.4m of Type B), $7.2m (plant and machinery omitted as capital), and $3.4m (no enhancement at all).

5. Basis Period & Loss Relief IRO ss.18, 18C, 19C

Assessable profits are normally computed on the accounting year ending within the year preceding the year of assessment (s.18(1)). Where a business commences or ceases partway through a year, ss.18C–18H set special opening/closing basis periods. Trading losses are carried forward indefinitely and set off against future assessable profits from the same source (s.19C) — there is no time limit, but no carry-back and no group relief between separate legal entities in Hong Kong (each company is assessed on its own profits).

Where a taxpayer has both "normal" and "concessionary rate" trading receipts (e.g. under a qualifying debt instrument or reinsurance concession), s.19CA/19CB impose a cross-set-off formula using a statutory adjustment factor rather than a straight one-for-one offset — see DIPN 8.

6. Foreign-Sourced Income Exemption (FSIE) Part 4, Division 3A

Division 3A (ss.15H onward, added by the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Ordinance 2022, effective 1 January 2023) deems specified categories of foreign-sourced income — interest, dividends, disposal gains on equity interests, and IP income — received in Hong Kong by an MNE entity to be Hong Kong-sourced unless the entity meets an economic substance requirement (for interest/dividends/disposal gains) or complies with the nexus approach (for IP income), or qualifies for the participation exemption (for dividends/disposal gains on substantial equity interests).

Practical effect A Hong Kong holding or treasury company receiving offshore dividends, interest, or IP royalties that would otherwise be treated as offshore (non-taxable) under the ordinary source principle may now be taxed on that income unless it can document adequate economic substance in Hong Kong or a qualifying participation/nexus position. This is a common trap in tax computations for group treasury/holding entities — always check FSIE before treating offshore passive income as automatically non-taxable.

7. Illustrations

11 worked illustrations back this page — DIPN-sourced (lease premiums, interest deduction restrictions, service company fee caps, foreign tax deductibility, bank interest exemption, prepaid expenses) plus Module 9 textbook examples (basis periods, loss relief, secured loan/interest flow-back tests), all cross-checked against current law.

Illustration — Interest deduction restricted by a tax-free secured deposit DIPN 13A

Taxpayer F borrows $1,000,000 at 5% interest, secured by a $1,000,000 deposit earning tax-exempt interest at 4%. Because the loan is secured on a deposit generating tax-free income, s.16(2A)/(2B) restrict the deduction: the $40,000 tax-free interest earned reduces the otherwise-deductible $50,000 loan interest, leaving only $10,000 deductible.

8. Computation Template

A standard working proforma for converting accounting profit into assessable profits for a Hong Kong company:

Net profit per audited financial statementsX
Add: Depreciation charged per accountsX
Add: Non-deductible expenses (s.17 items — capital expenditure, domestic/private expenses, excess retirement contributions, disallowed provisions, etc.)X
Less: Non-taxable income credited in the accounts (capital gains, FSIE-exempt offshore income, exempt bank interest)(X)
Less: Depreciation allowances per Part 6 (industrial/commercial buildings, plant & machinery pools — see the Depreciation & Allowances page)(X)
Assessable profitsX
Less: Losses brought forward (s.19C)(X)
Net assessable profits (charged at two-tiered rates — §2)X

9. Filing the Return: BIR51

Once the computation above is done, it needs to go on the actual return. The Profits Tax Return Guide walks through BIR51 (corporations) box by box — company details, the two-tiered rate election, supplementary forms S1–S22, tax data, and depreciation allowance boxes — each tied back to the sections above. The companion Box Finder lets you search by keyword (e.g. "two-tiered", "depreciation") to jump straight to the right box, across BIR51, BIR52 (persons other than corporations), and BIR54 (non-resident persons).

10. Source Documents

CAP112 sections referenced above: s.14, s.14AAC, s.15 (incl. Division 3A ss.15H–15R FSIE), s.16 (incl. 16A–16G), s.17, s.18/18C, s.19C. Consolidated text: Data/CAP112/.

Core DIPNs for this page (download from the IRD DIPN index and save into Data/DIPN/Profits-Tax/ — see checklist in that folder):

  • DIPN 1 — Profits Tax: Computing Assessable Profits / Revenue Recognition (HKFRS 15) / Measurement of Inventories
  • DIPN 3 — Apportionment of Expenses
  • DIPN 4 — Lease Premiums, Non-Returnable Deposits, Key/Tea Money, Construction Fees
  • DIPN 8 — Losses
  • DIPN 13 / 13A — Taxation of Interest Received / Deductibility of Interest Expense
  • DIPN 15 — Loss Relief Limitation, Leasing, GAAR, Loss Companies
  • DIPN 21 — Locality of Profits
  • DIPN 24 — Service Company "Type II" Arrangements
  • DIPN 28 — Deduction of Foreign Taxes
  • DIPN 34 — Exemption from Profits Tax (Interest Income) Order 1998
  • DIPN 39 — Digital Economy, E-Commerce and Digital Assets
  • DIPN 40 — Prepaid or Deferred Revenue Expenses
  • DIPN 42 — Taxation of Financial Instruments & Foreign Exchange Differences
  • DIPN 49 — Deduction of Capital Expenditure on Patent Rights, Know-how and Specified IP

Cross-reference: PwC Worldwide Tax Summaries — Hong Kong SAR, Corporate tax pages (saved copies in Data/PwC/).

Business — Profits Tax

Profits Tax by Entity

The same charge under s.14, but three materially different computations: sole proprietorship, partnership, and corporation. The partnership carries allocation mechanics on top, and only individuals can carry their share into personal assessment.

利得稅:三種實體同一條段,三種不同計算:獨資、合夥及法團。涵蓋 s.17(2) 對業主及其配偶的支付、合夥利潤分配與重新分配、法團合夥人與兩級制稅階的攝分,以及哪類業主可將分潤納入個人入息課稅。

1. Why the entity changes the computation

Profits tax has one charging section for all three. What differs is the rate, what counts as a deductible payment to the owner, and what happens after the assessable profit is struck.

The idea underneath all of it An unincorporated business is not separate from its owner. A sole proprietor cannot employ himself, and a partner cannot be an employee of his own partnership — so a "salary" to them is an appropriation of profit, not an expense. A company is a separate person, so it genuinely can employ its director and genuinely does pay them a salary.

Nearly every difference below follows from that one point. Once you see it, you do not have to memorise the table — you can derive it.

The second consequence is who bears the tax. A company pays its own profits tax and the director separately pays salaries tax on the salary. A sole proprietor's profit is taxed once, in the business — but the proprietor may then elect personal assessment to have it re-taxed at progressive rates after allowances. A company cannot elect at all.

2. The three side by side

PointSole proprietorshipPartnershipCorporation
Two-tiered rates 7.5% on the first $2m, 15% above 7.5% / 15% — but see §2b where a partner is a company 8.25% on the first $2m, 16.5% above
Salary to the owner Not deductible s.17(2) — an appropriation Not deductible s.17(2) Deductible — a director is an employee
Salary to the owner's spouse Not deductible s.17(2), even if genuinely employed Not deductible s.17(2) Deductible if genuine employment at a commercial rate
Owner's own mandatory MPF Deductible s.16AA, capped at $18,000 — self-employed contributions Deductible s.16AA for each partner n/a — the company's contributions for the director are ordinary staff costs
Interest on a loan from the owner Not deductible s.17(2) Not deductible s.17(2) Conditional — deductible only if s.16(2) is satisfied
Allocation between owners n/a Required — see §2 n/a
Personal assessment Available — the assessable profit enters the proprietor's PA Available to individual partners on their allocated share Not available — companies cannot elect
Losses Carried forward indefinitely, or set against other income under PA Allocated to partners; a corporate partner's share can shelter its own other profits Carried forward indefinitely against the company's own profits only
Return form BIR60 (individual), with the business schedule BIR52 BIR51
s.17(2) reaches the spouse, and that surprises people A salary to a sole proprietor's or partner's spouse is not deductible even where the spouse works full time for a commercial wage. Worse, the spouse is still chargeable to salaries tax on what they receive — so the same money is taxed in the business and again in the spouse's hands. The equivalent payment in a company is deductible. This is one of the sharper practical differences between the forms.

3. Sole proprietorship

One computation, one taxpayer. The whole assessable profit belongs to the proprietor, and the only question after that is whether personal assessment improves on it.

Illustration

Fiona carries on a design studio as a sole proprietor. The accounts for the year ended 31 March 2027 show a profit of $960,000, after charging a salary of $360,000 to Fiona, a salary of $180,000 to her husband (who works full time in the business at a commercial wage), and Fiona's own mandatory MPF contributions of $18,000. Depreciation allowances are $80,000.

Fiona — Profits Tax Computation · YA 2026/27
Profit per accounts960,000
Add: salary to the proprietor — s.17(2)360,000
Add: salary to the proprietor's spouse — s.17(2)180,000
Proprietor's own mandatory MPF — deductible, s.16AA0
1,500,000
Less: depreciation allowances(80,000)
Assessable profit1,420,000
Profits tax, unincorporated: $1,420,000 × 7.5% (within the first $2,000,000)106,500

Then two further consequences that are easy to forget:

The husband is still taxed His $180,000 is disallowed to the business but remains his employment income. Salaries tax: $180,000 − $145,000 basic allowance = $35,000 net chargeable income, at 2% = $700. The money is taxed twice.
Personal assessment is available — but here it is worse Fiona could elect PA on the $1,420,000. Net chargeable income would be $1,275,000, giving $198,750 at progressive rates (the standard-rate comparison on $1,420,000 gives $213,000, so progressive wins). That is well above the $106,500 profits tax she already pays. Do not elect.
The general shape Personal assessment helps a sole proprietor whose profit is low — where allowances and progressive rates beat a flat 7.5% — or who has property income or a loss to bring in. At $1.4m of profit the 17% marginal rate is already above 7.5%, so it costs money. Compute both; never assume.

4. Partnership

One assessment is raised on the partnership, not on the partners. But the profit must still be allocated partner by partner — because the allocation drives loss relief, personal assessment, and (where a partner is a company) the rate itself.

StepWhat happens
1Compute the partnership's assessable profit or adjusted loss in the ordinary way, adding back salaries and interest to partners and to partners' spouses under s.17(2).
2Allocate prior allocations first — the salaries and interest just added back go to the partner they relate to, not into the profit-sharing ratio.
3Share the balance in the profit-sharing ratio. The balance is often negative once the prior allocations are taken out.
4Reallocate so that no partner is left on the wrong side of zero: where the partnership has assessable profits, a partner cannot keep a loss share, and vice versa.
5Apply the rates — by partner if their natures differ (§2b).
Step 4 is the one candidates miss If the partnership's bottom line is a profit, no partner may be allocated a loss: any negative share is reallocated to the profit-making partners in proportion. If the partnership's bottom line is a loss, the mirror applies — any partner allocated a profit has it reallocated to the loss-making partners. The June 2025 examiner's report names this explicitly.

A full worked partnership allocation, with a loss per the accounts that adjusts to a profit, is Question 9 on the ACCA TX-HKG page →

5. Partnerships with a corporate partner

A company can be a partner. When it is, the partnership contains partners taxed at different rates, and the two-tiered threshold has to be shared out.

The rule Each partner's share of the assessable profits is taxed at that partner's own rate — 8.25%/16.5% for a corporate partner, 7.5%/15% for an individual. And the $2,000,000 first-tier band is itself apportioned between the partners in their profit-sharing ratio. The partnership does not get one $2,000,000 band at a single rate.

Illustration

Novena Trading is a partnership with assessable profits of $3,000,000 for YA 2026/27. The partners share profits equally: Carol, an individual, and Elm Holdings Limited, a company.

Novena Trading — profits tax by partner · YA 2026/27
Carol (individual)Elm Holdings LtdTotal
Share of assessable profits, 50 : 501,500,0001,500,0003,000,000
Share of the $2,000,000 first-tier band
apportioned in the profit-sharing ratio
1,000,0001,000,0002,000,000
First tier, at the partner's own rate1,000,000 × 7.5%
= 75,000
1,000,000 × 8.25%
= 82,500
157,500
Balance, at the partner's own rate500,000 × 15%
= 75,000
500,000 × 16.5%
= 82,500
157,500
Profits tax150,000165,000315,000
What the answer would have been in a uniform partnership
CompositionProfits tax on $3,000,000
All partners individuals300,000
Mixed, 50 : 50 as above315,000
All partners corporate330,000

The mixed partnership lands exactly between the two — which is the point. A single blended rate applied to the whole $3,000,000 would not produce $315,000, and computing the first tier once at either rate would be wrong for one of the partners.

Loss relief for a corporate partner Where the partnership makes a loss, a corporate partner's allocated share can be set against that company's own other assessable profits — the loss is not trapped in the partnership. An individual partner's share goes into their personal assessment or is carried forward against future shares of the same partnership. The examining team noted that candidates were "not familiar with the loss relief for corporate partners".

6. How a partner's share flows into personal assessment

This is the link between this page and Personal Assessment, and it only exists for individual partners.

Partnership — assessable profits computed and allocated→
Individual partner's allocated share enters their personal assessment as net assessable profits, alongside their salary and property income✓
Corporate partner's allocated share — no personal assessment; the company is assessed on its share at corporate rates and that is the end of it✗

Carol's position, continuing §5. Her $1,500,000 share has already borne $150,000 of profits tax within the partnership assessment. If she elects personal assessment, that $1,500,000 becomes part of her total income:

Share of partnership assessable profits1,500,000
Less: basic allowance D26 exam (YA 2025/26): $132,000(145,000)
Net chargeable income1,355,000
Progressive rates212,350
Standard-rate comparison: $1,500,000 × 15%225,000
Tax under personal assessment212,350
Against her share of the partnership profits tax already charged150,000
Electing would cost her62,350
The pattern, across both illustrations on this page Fiona at $1.42m and Carol at $1.5m both find personal assessment worse. That is not a coincidence. Business profits are taxed at 7.5% in an unincorporated business, and the progressive marginal rate reaches 17% once net chargeable income passes $200,000. For a profitable business with no other reliefs to unlock, PA is usually a cost.

It turns beneficial when there is something for it to unlock: mortgage interest on a let property, a business loss to set against salary, or allowances going unused because the income is not employment income. Those are the cases to look for — not size of profit.

7. Corporation

The standard case, and the one the general profits tax format is written for. The company is a separate person, so payments to its directors are real expenses.

Illustration — the same business as §3, incorporated

Fiona Ltd carries on the same design studio. The accounts show the same profit of $960,000 after the same salary of $360,000 to Fiona, now a director, and $180,000 to her husband, a genuine employee. Depreciation allowances are $80,000.

Fiona Ltd — Profits Tax Computation · YA 2026/27
Profit per accounts960,000
Director's salary — deductible, no add-back0
Salary to the director's spouse, genuinely employed — deductible0
Less: depreciation allowances(80,000)
Assessable profit880,000
Profits tax, corporation: $880,000 × 8.25%72,600

The salaries are then taxed in the recipients' hands, which the sole-proprietorship version largely avoided for Fiona:

Fiona — salaries tax on $360,000 ($215,000 net chargeable income)18,550
Husband — salaries tax on $180,000 ($35,000 net chargeable income)700

8. Same business, three forms — the figures side by side

The identical trade, earning $1,500,000 before remunerating the owner and spouse
Sole proprietorshipCorporation
Profit per accounts960,000960,000
Add back: owner's and spouse's salaries — s.17(2)540,000—
Less: depreciation allowances(80,000)(80,000)
Assessable profit1,420,000880,000
Profits tax106,500 @ 7.5%72,600 @ 8.25%
Owner's salaries tax— no salary in law18,550
Spouse's salaries tax700700
Total tax borne107,20091,850

The company pays tax at the higher headline rate and still comes out $15,350 lighter, because $540,000 of remuneration moves out of the 7.5%-plus-nothing charge and into the progressive salaries tax bands, where the first $145,000 is covered by an allowance and the next slices are taxed at 2%–14%.

Read that as a structural point, not as advice The comparison isolates one variable to show how s.17(2) drives the difference. A real incorporation decision turns on much more — limited liability, audit and filing costs, business registration, stamp duty on any transfer of the business, how profits are actually extracted, and what happens on a later sale. The figures above are an illustration of a mechanism, not a recommendation. And the answer reverses at other profit levels: push the profit high enough and the 17% salaries tax band overtakes the 8.25% corporate rate.

9. Exam checklist

Before you startAsk
Which entity is it?Sole proprietorship, partnership or company. This sets the rate before anything else. Answering an unincorporated question at 8.25% loses the rate marks and every figure after them.
Is anyone paid who is the owner, or married to one?In an unincorporated business both are disallowed under s.17(2). In a company both are deductible if genuine.
Whose MPF is it?The proprietor's or partner's own mandatory contributions are deductible under s.16AA, capped at $18,000. Their spouse's are not.
Is there a corporate partner?Then the rates differ by partner and the $2,000,000 band is apportioned in the profit-sharing ratio.
Does anyone have a share on the wrong side of zero?Reallocate. No loss share when the partnership is in profit; no profit share when it is in loss.
Has the question asked about personal assessment?Only an individual can elect. Compute it both ways and say which is better — the answer is often "do not elect", and saying so with figures is the mark.
Is the spouse's disallowed salary still taxed?Yes, on the spouse. If the question gives their personal circumstances, it wants that computation too.

Profits Tax rules → · the general format → · worked partnership allocation → · Personal Assessment →

10. Source documents

  • IRO (Cap. 112) ss.14, 16AA, 16(2), 17(2), 22, 22A, 22B — charge, self-employed MPF, interest, disallowed payments, partnership assessment and allocation—
  • IRD — Profits Tax and the two-tiered rates guidance, including apportionment of the first-tier band in a partnershipread 24 Sep 2026
  • IRD — Allowances, Deductions and Tax Rate Table (pam61e), YA 2026/27read 24 Sep 2026
  • ACCA TX-HKG examiner's report, June 2025 — partnership allocation and corporate partner loss relief identified as weakread 24 Sep 2026
  • All illustrations on this page are original; every figure computed and verified24 Sep 2026
Individual — Salaries Tax

Salaries Tax

Inland Revenue Ordinance (Cap. 112), Part 3 — charged on Hong Kong-source income from an office, employment of profit, or pension.

薪俸稅涵蓋香港受僱工作、入息、福利、可扣除支出、個人免稅額、標準稅率上限及個人入息課稅銜接。

1. Overview & Charging Basis IRO s.8

Salaries tax is charged on income arising in or derived from Hong Kong from an office, employment of profit, or pension (s.8(1)) — again a territorial-source tax, not a residence-based one. Whether employment income is "Hong Kong employment" or "non-Hong Kong employment" is decided on the "totality of facts" test from Goepfert — the three key factors are: (1) where the employment contract was negotiated and is enforceable, (2) the residence of the employer, and (3) where the employee's remuneration is paid (see DIPN 10).

The 60-day rule — s.8(1A)(b)/(1B) Income from services rendered wholly outside Hong Kong by a person not employed by the Government (and not ship/aircraft crew) is excluded from the charge — unless the person visited Hong Kong for more than 60 days in the basis period, in which case services rendered during those visits are brought back into charge.

Directors' fees from a Hong Kong resident company are always Hong Kong-sourced regardless of where the director renders services. Income taxed in a DTA territory that gives a s.50 credit is excluded from the s.8(1A)(c) exemption route (must use the credit mechanism instead, not double relief).

2. Rates & Standard Rate Cap IRO s.13, Schedule 2

Progressive rates on net chargeable income (2025/26 and continuing into 2026/27 basis) — Schedule 2
BandRate
First HKD 50,0002%
Next HKD 50,000 (50,001–100,000)6%
Next HKD 50,000 (100,001–150,000)10%
Next HKD 50,000 (150,001–200,000)14%
Remainder (above 200,000)17%

Under s.13, tax computed progressively on net chargeable income (i.e. after allowances) is capped at a standard-rate calculation applied to net total income (i.e. before personal allowances, but after concessionary deductions): 15% on the first HKD 5,000,000, 16% on the remainder. The taxpayer pays whichever of the two computations is lower — this matters most for higher earners with large personal allowances.

One-off relief Inland Revenue (Amendment) Ordinance 2026 (gazetted 22 May 2026): 100% reduction of salaries tax/personal assessment tax for YA 2025/26, capped at HKD 3,000. (Source: PwC, reviewed 22 Jul 2026 — verify against the gazetted ordinance.)

3. Taxable / Non-Taxable Income

StatusItemBasis
TaxableSalary, wages, bonus, commission, leave pay for services rendered in Hong Kongs.8(1)(a), s.8(1A)(a)
TaxableDirector's fee from a Hong Kong resident companys.8(1)(a) — sourced to the company's residence, not where services are performed
TaxablePension attributable to Hong Kong employment/offices.8(1)(b)
TaxableEmployer-provided holiday journey benefits — actual cost to employer, regardless of convertibility, apportioned for business-cum-holiday tripss.9(2A)(c); DIPN 41
TaxableShare option gains at exercise (HK-employment portion) and share award vesting benefitss.9(1)(d)/(4)/(5); DIPN 38
TaxableFringe benefits convertible into money, or specifically deemed by s.9(1)(a)(iv) "liability test" (e.g. employer settling the employee's personal debt/liability)DIPN 16
Non-taxableIncome from services rendered wholly outside Hong Kong (non-Government employee, ≤60 days HK visits)s.8(1A)(b), s.8(1B)
Non-taxableIncome already taxed in a non-DTA territory of substantially the same nature, tax actually paids.8(1A)(c)
Non-taxableGenuine reimbursement of business expenses (no personal benefit)General principle — not "income from employment"

4. Deductible / Non-Deductible Items IRO s.12

The general test (s.12(1)(a)) is stricter than the profits tax test — expenses must be "wholly, exclusively and necessarily" incurred in producing the assessable income (not merely "to the extent"), and domestic/private expenses and capital expenditure are excluded outright. In practice very few ordinary employment expenses pass this test (see DIPN 9).

StatusItemBasis / cap (2026/27)
DeductibleOutgoings/expenses wholly, exclusively and necessarily incurred in producing the income (rare in practice for employees)s.12(1)(a)
DeductibleSelf-education expensess.12(1)(e) — capped at HKD 100,000
DeductibleMandatory MPF contributionsCapped at HKD 18,000
DeductibleHome loan interest (ss.26E/26F)HKD 100,000 (120,000 if a qualifying child born after 25 Oct 2023); up to 20 years of assessment; apportioned among joint owners/tenants in common (DIPN 35)
DeductibleDomestic rent (new, non-owner-occupiers)HKD 100,000 (120,000 with qualifying child)
DeductibleElderly residential care expenses (s.26D)HKD 110,000 per parent/grandparent; mutually exclusive with the dependent parent/grandparent allowance (DIPN 36)
DeductibleApproved charitable donations (s.26C)Min. HKD 100 aggregate; capped at 35% of income after other deductions (DIPN 37)
DeductibleHealth insurance premiums under VHIS Certified Plans (ss.26H–26M)HKD 8,000 per insured person (DIPN 56)
DeductibleQualifying annuity premiums + MPF voluntary contributions (ss.26N–26U)Combined cap HKD 60,000/year, TVC deducted first (DIPN 57)
DeductibleAssisted reproductive services expensesHKD 100,000 (from 2024/25)
Non-deductibleCost of travel between home and workplaces.12(1)(a) excludes domestic/private expenses (DIPN 9)
Non-deductibleClothing, entertainment expenses of a personal natureDIPN 9
Non-deductibleExcess deductions beyond each item's statutory cap (e.g. donations above 35%, VHIS above HKD 8,000/insured)Excess simply lapses — no carry-forward for salaries tax deductions (unlike profits tax losses)

5. Personal Allowances IRO Part 5, ss.28–33

Key allowances (HKD). The second column is the basis examined by ACCA TX-HKG from J25 through D26 — IRD publishes 2024/25 and 2025/26 as one column, so the figures are identical across both.
AllowanceYA 2026/27 — currentYA 2024/25 & 2025/26 — D26 exam
Basic allowance145,000132,000
Married person's allowance290,000264,000
Child allowance (1st–9th child)140,000 each (280,000 in year of birth + following year)130,000 each (260,000)
Child allowance — 2nd and subsequent child born on/after 16 Sep 2026 proposed160,000 each (320,000 in year of birth + following year)
Single parent allowance145,000132,000
Dependent parent/grandparent allowance (60+, not residing with taxpayer)55,00050,000
Dependent parent/grandparent allowance (60+, residing with taxpayer)110,000100,000
Dependent parent/grandparent allowance (55–59)27,500 / 55,000 (not residing / residing)25,000 / 50,000
Dependent brother/sister allowance37,50037,500
Personal disability allowance75,00075,000
Disabled dependant allowance75,000 per dependant75,000

Child allowance claim period for the enhanced "year of birth" rate was extended from 1 to 2 years effective YA 2026/27 — check whether this affects the year you're computing.

Proposed — 2026 Policy Address, 16 September 2026 The Chief Executive announced that child allowance will rise from HKD 140,000 to HKD 160,000 for a taxpayer's second and subsequent children born on or after 16 September 2026 (claimable until age 25, on the usual full-time education / disability conditions). The enhanced additional child allowance for the year of birth and the following year rises to HKD 160,000 on the same basis, so those two years give HKD 320,000 per qualifying child. Intended to take effect from YA 2026/27, but it requires an amendment ordinance — until that is enacted, the enacted figure for every child remains HKD 140,000. First-born children are not covered by the increase.

6. Personal Assessment IRO s.41

Personal Assessment is an election (not automatic) available to individuals (and, if both elect, jointly for married couples under s.41(1A)) that aggregates all sources of income — including property tax and profits tax from an unincorporated business — into one computation, deducting personal allowances and applying salaries-tax-style progressive rates. It is beneficial mainly where the taxpayer has property tax or unincorporated-business profits tax that would otherwise get no benefit from personal allowances, or has losses in one source that can offset income in another.

Joint assessment (s.10(2), distinct from Personal Assessment) lets a married couple be taxed as one for salaries tax where beneficial — typically where one spouse has income below the value of their own allowances (DIPN 18).

Personal Assessment has its own page This summary is here because Personal Assessment is where Salaries Tax meets the other two heads of charge. The full treatment — eligibility and the residence tests, the 2018/19 change letting married persons elect separately, election and withdrawal time limits, the three-step computation and the standard-rate cap, what is deductible, and four worked illustrations including one where electing costs money — is on the Personal Assessment page.

Full Personal Assessment page → · 3 further election illustrations from Module 9 →

7. Illustrations

14 worked illustrations back this page — DIPN-sourced (joint assessment, home loan interest apportionment, VHIS/donation caps, share option vesting) plus Module 9 textbook examples (the 60-day rule, housing benefit valuation, termination gratuities, child allowance eligibility, a full computation, and 3 Personal Assessment election scenarios), all cross-checked against current YA 2026/27 rates and allowances.

Illustration — Joint assessment saves tax vs separate taxation DIPN 18

Mr A earns $680,000, Mrs A earns $100,000. Taxed separately, their combined liability is $23,030. Electing joint assessment under s.10(2) — pooling income and allowances — reduces the combined liability to $17,505, because Mrs A's unabsorbed allowances/deductions offset Mr A's higher-rate income.

8. Computation Template

Income from employment/office/pension (Hong Kong-sourced, per §3)X
Add: taxable fringe benefits, share-based benefits, holiday journey benefitsX
Assessable incomeX
Less: outgoings/expenses under s.12(1)(a), self-education expenses(X)
Net assessable incomeX
Less: concessionary deductions (home loan interest, donations, MPF/TVC/annuity, elderly care, VHIS, rent — each subject to its own cap)(X)
Net total incomeX
Less: personal allowances (§5)(X)
Net chargeable incomeX
Tax at progressive rates (§2) — compare against the standard-rate cap on net total income and pay the lowerX

9. Source Documents

CAP112 sections referenced above: s.8, s.9, s.12, s.13, Part 5 (ss.28–33), s.41, ss.26C/26D/26E/26F/26H–26M/26N–26U. Consolidated text: Data/CAP112/.

Core DIPNs for this page (download and save into Data/DIPN/Salaries-Tax/):

  • DIPN 9 — Major Deductible Items under Salaries Tax
  • DIPN 10 — The Charge to Salaries Tax
  • DIPN 16 — Taxation of Fringe Benefits
  • DIPN 18 — Assessment of Individuals under Salaries Tax and Personal Assessment
  • DIPN 23 — Recognized Retirement Schemes
  • DIPN 25 — Service Company "Type I" Arrangements
  • DIPN 33 — Insurance Agents
  • DIPN 35 — Home Loan Interest (ss.26E & 26F)
  • DIPN 36 — Elderly Residential Care Expenses (s.26D)
  • DIPN 37 — Approved Charitable Donations (s.26C)
  • DIPN 38 — Employee Share-Based Benefits
  • DIPN 41 — Taxation of Holiday Journey Benefits
  • DIPN 56 — Health Insurance Premiums (VHIS, ss.26H–26M)
  • DIPN 57 — Annuity Premiums and MPF Voluntary Contributions (ss.26N–26U)

Cross-reference: PwC Worldwide Tax Summaries — Hong Kong SAR, Individual tax pages (saved copies in Data/PwC/).

Business — Property Tax

Property Tax

Inland Revenue Ordinance (Cap. 112), Part 2 — charged on the owner of land or buildings in Hong Kong, on the net assessable value.

物業稅說明物業稅的納稅人、租金收入、差餉、20% 法定修葺免稅額、不可收回租金及公司業主與利得稅的互動。

1. Overview & Charging Basis IRO s.5

Property tax is charged for each year of assessment on every person who owns land or buildings in Hong Kong, computed at the standard rate on the net assessable value — regardless of whether the owner carries on any trade or business. It is a tax on ownership + letting, not on trading profit as such.

Statutory text — s.5(1) "Property tax shall...be charged for each year of assessment on every person being the owner of any land or buildings or land and buildings wherever situate in Hong Kong and shall be computed at the standard rate on the net assessable value of such land or buildings..."
Current rate
Standard rate applied to net assessable value15%

Owner-occupied property generates no rental consideration and therefore has no assessable value — no property tax arises. Where the owner of the land is not the owner of the buildings on it, separate assessments are made for each (s.5(1)(b)).

Traps in the property tax computation

Three points the June 2026 examining team reported as weak 1. Compute each property separately. Where a taxpayer owns more than one let property, property tax is computed property by property, not on the aggregate. Each gets its own assessable value, its own rates deduction and its own 20% allowance.

2. Repairs and replacements get no separate deduction. Actual spending on repairs, redecoration or replacing fittings is deemed to be covered by the 20% statutory allowance — however much was really spent. Candidates could say the cost was not deductible but could not explain why.

3. There are no depreciation allowances under property tax. Replacing air-conditioners or other plant in a let property attracts no depreciation allowance, because Part 6 does not apply to the property tax charge. If the owner is a company carrying on business the position differs — the income is then within profits tax, where allowances are available.
The rental deposit — two different things A deposit taken at the start of a lease is not assessable income; it is security held for the tenant. A deposit later forfeited and retained is set off against irrecoverable rent. The June 2026 report names both including the deposit as income and failing to set off a forfeited deposit as common errors.

2. Net Assessable Value IRO s.5(1A), s.5B, s.7C

Assessable value (s.5B(2)) is the consideration in money or money's worth payable for the right to use the land/buildings during the year — i.e. rent and other consideration receivable, not merely received. Net assessable value (s.5(1A)) then deducts:

Assessable value (rent/consideration receivable for the year)X
Less: irrecoverable consideration proved bad during the year (s.7C)(X)
Less: rates paid by the owner, if the owner agreed to bear them(X)
Less: statutory 20% allowance for repairs and outgoings (on the balance after rates)(X)
Net assessable valueX

The 20% repairs/outgoings allowance is flat and statutory — it applies regardless of the owner's actual repair costs, and cannot be varied by claiming higher actual expenditure. Consideration recovered in a later year, having previously been written off as irrecoverable under s.7C, is brought back into that later year's assessable value (s.7C(2)).

Lease premiums paid up front are deemed under s.5B(3)/(4) to be payable in equal monthly instalments spread over the period of the right of use, capped at a maximum of 3 years — even if the actual lease term is longer. See the DIPN 4/DIPN 14 illustrations below.

3. Taxable / Non-Taxable Items

StatusItemBasis
TaxableRent receivable for the year (whether or not actually received)s.5B(2)
TaxableLease premiums / non-returnable deposits / key money, spread over up to 3 yearss.5B(3)/(4); DIPN 4, DIPN 14
TaxableConsideration for services/benefits connected with the right of use (e.g. furniture, management services bundled into rent)s.5B(6)
Non-taxableOwner-occupied property (no rent receivable)No assessable value arises — s.5(1)
Non-taxableRent/consideration proved to have become irrecoverable during the years.7C(1)
Deduction (fixed)Rates paid by owner + flat 20% repairs/outgoings allowances.5(1A)(b)

4. Corporate Interaction with Profits Tax IRO s.25, s.5(2)(a)

For a corporation carrying on a trade, profession or business in Hong Kong, property tax and profits tax can otherwise double-tax the same rental income. Two relief mechanisms apply:

  • Set-off (s.25): where the rental profits form part of the corporation's trading profits (or the property is used to produce chargeable profits), profits tax payable is reduced by the property tax already paid on that property. If property tax paid exceeds the profits tax payable, the excess is refunded (s.25, proviso (b), via s.79).
  • Upfront exemption (s.5(2)(a)): instead of paying property tax and later claiming the set-off, a corporation entitled to the s.25 set-off may apply in writing to the Commissioner for the property to be exempted from property tax altogether. The corporation must notify the Commissioner within 30 days of any change in ownership/use affecting the exemption (s.5(2)(c)).
Practical note Non-corporate owners (individuals, partnerships) do not get the s.25 set-off/exemption against profits tax in the same way — they may instead elect Personal Assessment (IRO s.41) to have property tax effectively absorbed into a single personal-assessment computation where advantageous. See the Salaries Tax page for Personal Assessment.

5. Illustrations

7 worked illustrations back this page — DIPN-sourced (premium spreading, the NAV computation chain) plus Module 9 textbook examples (a full 3-property NAV computation, irrecoverable-rent carry-back, the profits-tax set-off), all using the current 15%/20% rates.

Illustration — Premium spread over the statutory 3-year cap DIPN 14

A $60,000 premium is paid for a 5-year lease running from 1 June 2006 to 31 May 2011 (60 months). Because s.5B(4) caps the spreading period at 3 years (36 months) even though the lease itself runs 5 years, the premium is spread over 36 months only — nothing is assessed for the remaining 24 months of the lease.

6. Computation Template

Rent and other consideration receivable for the yearX
Add: lease premium instalment for the year (s.5B(3)/(4), capped at 3 years)X
Less: irrecoverable rent proved bad in the year (s.7C)(X)
Assessable valueX
Less: rates paid by owner (if owner bears them)(X)
Less: 20% statutory allowance for repairs and outgoings(X)
Net assessable valueX
Property tax payable (15% standard rate)X
Less: set-off against profits tax if corporation and s.25 conditions met(X)

7. Source Documents

CAP112 sections referenced above: s.5, s.5(1A), s.5(2), s.5B, s.7A, s.7C, s.25. Consolidated text: Data/CAP112/.

Core DIPNs for this page (download and save into Data/DIPN/Property-Tax/):

  • DIPN 14 — Property Tax
  • DIPN 4 — Lease Premiums, Non-Returnable Deposits, Key/Tea Money, Construction Fees (shared with Profits Tax)

Cross-reference: PwC Worldwide Tax Summaries — Hong Kong SAR, Corporate — Other Taxes page (saved copies in Data/PwC/).

Individual — Personal Assessment

Personal Assessment

Inland Revenue Ordinance (Cap. 112), Part 7 (ss.40–43) — not a tax, but an election that re-computes Property Tax, Profits Tax and Salaries Tax together at progressive rates, after allowances.

個人入息課稅並非稅種,而是一項選擇:把物業、業務及受僱入息合併計算,按累進稅率並扣除免稅額。涵蓋資格、2018/19 年起可分開選擇的改動、時限、標準稅率上限,以及甚麼情況下選擇反而更貴。

1. What Personal Assessment is IRO s.41

Hong Kong levies direct tax under three separate heads — Salaries Tax, Profits Tax and Property Tax. Personal Assessment (PA) is not a fourth head of charge. It is a relief: an individual may elect to have all three sources aggregated into one computation, taxed at salaries-tax progressive rates after personal allowances, instead of being taxed separately at the standard rate on each source.

The one-line test for whether PA can possibly help Property Tax and Profits Tax are charged at the standard rate with no personal allowances. Salaries Tax already gets progressive rates and allowances. So PA can only help someone with property income or unincorporated-business profits. A taxpayer whose only income is employment income cannot benefit from electing — there is nothing for the election to unlock.

The election is annual, must be made in writing, and is not automatic. IRD will not apply it for you, though where an election has been made and turns out to be disadvantageous, the assessor will raise the separate assessments instead and note on the demand that PA was not to your benefit.

Distinguish from Joint Assessment Joint assessment (s.10(2)) is a Salaries Tax mechanism for married couples — it pools employment income only. Personal Assessment (s.41) pools all three heads of charge. They are different elections under different sections, and the exam trap is treating them as the same thing. See Salaries Tax §6.

2. Who may elect IRO s.41(1), s.41(4)

The conditions changed from YA 2018/19. Both are set out because the older rule still governs any earlier year still under assessment or objection.

Year of assessmentConditions
2018/19 onwards
current
The individual is 18 or over (or under 18 if both parents are dead); and the elector is personally either ordinarily resident in Hong Kong or a temporary resident.
Up to 2017/18 Same age test; but the residence test could be satisfied by the spouse — the elector, or if married their spouse, had to be ordinarily resident or a temporary resident.

The substantive change is that from 2018/19 the elector must qualify on their own residence. Piggy-backing on a spouse's residence status no longer works.

TermMeaning
Ordinarily resident
s.41(4)
Resides in Hong Kong voluntarily and for a settled purpose (education, business, employment, family) with a sufficient degree of continuity — habitually and normally resident apart from temporary or occasional absences, living here as an ordinary member of the community for all the purposes of daily life. Ultimately a question of fact. The Ordinance does not define it further; the case law is Lysaght v CIR (regular visits of substantial duration year to year) and Cooper v Cadwalader (maintaining a place of abode).
Temporary resident Stays in Hong Kong for more than 180 days during the year of assessment for which the election is made, or more than 300 days in two consecutive years of assessment, one of which is the year of election.
Not the same as a permanent identity card "Ordinarily resident" is a factual test about how and where someone actually lives. Holding a Hong Kong permanent identity card is evidence, not the test, and someone can hold one while no longer ordinarily residing here. Conversely a non-permanent resident who is physically here for enough days qualifies as a temporary resident and may elect.

Deceased taxpayers. Where a person who was eligible to elect dies, the executor has the same right of election over the deceased's total income as the deceased would have had.

3. Married couples IRO s.41(1A), s.42(2)

Separate election has been available since YA 2018/19 The Inland Revenue (Amendment) (No. 9) Ordinance 2018 relaxed what had been a hard joint-election requirement. From YA 2018/19, a married person may elect for Personal Assessment separately from, or jointly with, their spouse.
SituationWho elects
2018/19 onwards, general ruleEither spouse may elect on their own. A joint election remains available where either or both are eligible and both have income assessable under the Ordinance.
Already jointly assessed under Salaries TaxThe PA election must be made jointly. A couple who elected joint assessment under s.10(2) cannot then split for PA.
Up to 2017/18Where both spouses had assessable income and were not living apart, the election had to be made by both. If one refused, neither could elect.

Where a joint election is made, each spouse's total income as appropriately reduced is aggregated into a joint reduced total income, the married person's allowance and other allowances are deducted from the joint figure, and the tax is computed once. The total tax is then apportioned between the spouses in the ratio of their respective reduced total incomes, and each receives their own notice of assessment and demand for payment.

Why the 2018/19 change matters in practice Under the old joint-election rule, electing meant each spouse necessarily learned the other's income and business losses. A spouse who wanted to keep that private could simply refuse, and the couple lost the relief entirely. Separate election removes that veto.

4. Time limits — election and withdrawal IRO s.41(2), s.41(3)

ActionDeadline
Election The later of:
  • 2 years after the end of the year of assessment concerned — so for YA 2026/27, not later than 31 March 2029; or
  • 2 months after the issue of a notice of assessment or additional assessment for that year.
Withdrawal Within 6 months of the date the Personal Assessment is issued, or such longer period as the Commissioner considers reasonable. Where the election was made jointly, the withdrawal must also be joint.

An election is made in writing — in practice by completing the relevant section of the Tax Return (BIR60), or on Form IR76C.

Withdrawal is close to one-way Once an election is withdrawn, the taxpayer may not elect again for that same year unless the Commissioner considers a re-election appropriate. Because the two-year election window is generous but the six-month withdrawal window is short, the safer sequence is to compute both outcomes before electing rather than electing speculatively and unwinding it later.

5. The computation, step by step IRO s.42, s.42A, s.43

Three steps: aggregate, deduct, then compare against the standard rate.

StepWhat happens
1Aggregate income chargeable to Property Tax, Salaries Tax and Profits Tax into total income.
2Deduct, in order: interest on money borrowed to produce property income → concessionary deductions → business losses of the year → PA losses brought forward. This gives reduced total income. Then deduct personal allowances to give net chargeable income.
3Compute tax as the lower of: progressive rates on net chargeable income, or the standard rate on reduced total income.
The standard-rate cap applies to PA too — and on the right base The cap compares progressive tax on net chargeable income (after allowances) against standard rate on reduced total income (before allowances). Applying the standard rate to the post-allowance figure is a classic error: it uses the wrong base and understates the cap.

What goes into "total income"

SourceFigure brought in
Property
Net assessable value
Rental income + recovered bad rent − irrecoverable rent = assessable value; less rates agreed and paid by the landlord; less the 20% statutory deduction. See Property Tax §NAV.
Employment
Net assessable income
Assessable income less s.12(1)(a) outgoings, s.12(1)(b) depreciation allowances and s.12(1)(e) self-education, plus any s.12(5) balancing charge. Note this is after self-education but before concessionary deductions — those are taken later, at step 2. See Salaries Tax §4.
Business
Net assessable profits
Profits of every sole proprietorship, plus the individual's share from each partnership — after offsetting losses brought forward and after approved charitable donations already allowed in the profits tax computation. See Profits Tax §5.
Only Hong Kong-source income enters PA aggregates income chargeable under the three heads. Offshore profits that were never chargeable to Profits Tax do not become chargeable by electing PA — and correspondingly an offshore business loss cannot be brought in to shelter Hong Kong income.

6. What is deductible under Personal Assessment

StatusItemBasis / cap (2026/27)
DeductibleInterest on money borrowed to produce property income — the deduction PA exists forCapped at the net assessable value of that individual property; no excess relief and no carry-forward (Board of Review D51/04)
DeductibleApproved charitable donationss.26C — aggregate min. HKD 100, capped at 35% of income after other deductions
DeductibleElderly residential care expensess.26D — HKD 110,000 per parent/grandparent; mutually exclusive with the dependent parent allowance
DeductibleHome loan interestss.26E/26F — HKD 100,000 (120,000 with a qualifying child); up to 20 years of assessment
DeductibleVHIS qualifying premiumsss.26H–26M — HKD 8,000 per insured person
DeductibleQualifying annuity premiums + MPF voluntary contributionsss.26N–26U — combined cap HKD 60,000
DeductibleDomestic rentsHKD 100,000 (120,000 with a qualifying child)
DeductibleAssisted reproductive service expensesHKD 100,000
DeductibleBusiness losses of the year, and PA losses brought forwardThe other reason to elect — a sole-proprietorship loss can shelter salary and property income in the same year
DeductiblePersonal allowancesBasic 145,000 / married 290,000 for YA 2026/27 (132,000 / 264,000 on the D26 exam basis) — the full table is on Salaries Tax §5
Non-deductiblePrivate and domestic expenses generallyPA does not open up deductions that no head of charge allows. It only lets you take, against aggregated income, the reliefs the Ordinance already grants.
Non-deductibleOffshore business lossesNever chargeable, so never available for set-off
Non-deductibleMortgage interest exceeding that property's NAVThe excess lapses — it cannot create or increase a loss
Don't confuse the two interest deductions Interest to produce property income (this section, capped at that property's NAV) is a different relief from home loan interest under ss.26E/26F (capped at HKD 100,000, for a dwelling the taxpayer occupies). A let property that is also mortgaged attracts the first; an owner-occupied home attracts the second. They are not interchangeable and a single property will not normally attract both.

7. When it helps — and when it does not

PA is likely to help where

  • Property is mortgaged — Property Tax gives no relief at all for loan interest.
  • There is a business loss to set against salary or property income in the same year.
  • Total income is low enough that the progressive rates average out below the standard rate.
  • Personal allowances are unused because the income is property or business income rather than salary.
  • Concessionary deductions (donations, elderly care) are being wasted against income that gets no relief for them.

PA is unlikely to help where

  • The only income is employment income — Salaries Tax already applies progressive rates and allowances, so there is nothing to gain.
  • Total income is high: the 17% marginal rate exceeds the 15% standard rate, so aggregating drags property or business income up to 17%.
  • The property is unmortgaged and allowances are already fully absorbed elsewhere.

Because the marginal progressive rate (17%) is above the standard rate (15%), PA is a relief that reverses into a cost once income is large enough. It must be computed both ways, not assumed.

8. Worked illustrations

Adapted from IRD's own worked examples in A Brief Guide to Personal Assessment (pam37e). IRD's leaflet computes them at YA 2025/26 allowances; every figure below has been recomputed at YA 2026/27 rates (basic allowance 145,000, married person's allowance 290,000), so the answers deliberately differ from the leaflet's.

One-off Budget reductions excluded IRD's examples net off a 100% tax reduction capped at HKD 3,000 for 2025/26. No equivalent has been assumed here for 2026/27 — check the current Budget before treating any figure below as the final net tax payable.
Illustration 1 — Mortgaged property, no other income IRD pam37e Example 1, recomputed at 2026/27

Miss Chan, single, receives monthly rent of $40,000 from a mortgaged property and paid $42,000 of loan interest during the year.

Without election — Property TaxHKD
Net assessable value ($40,000 × 12 × 80%)384,000
Property tax at the standard rate, 15%57,600
With election — Personal AssessmentHKD
Net assessable value384,000
Less: mortgage interest (within NAV, so allowed in full)(42,000)
Reduced total income342,000
Less: basic allowance D26 exam (YA 2025/26): $132,000(145,000)
Net chargeable income197,000
Progressive rates: 2%/6%/10% on the first three $50,000 bands, 14% on the remaining $47,00015,580
Standard-rate comparison: 15% × 342,000 reduced total income51,300
Tax payable — the lower of the two15,580

Electing saves $42,020 ($57,600 − $15,580). Both reliefs are doing work: Property Tax gives no deduction for mortgage interest and no personal allowance, and PA supplies both. IRD's own 2025/26 version of this example, with a $132,000 basic allowance and the $3,000 one-off reduction, gives tax of $14,700 and a saving of $42,900.

Illustration 2 — Business loss set against salary IRD pam37e Example 2, recomputed at 2026/27

Mr Lee has salary income of $400,000 and incurred a business loss of $100,000 in the same year.

Without electionHKD
Salaries tax: ($400,000 − $145,000) = $255,000 at progressive rates25,350
Profits tax: a loss, so nil — the loss is carried forward, unused this year0
Total25,350
With election — Personal AssessmentHKD
Salary income400,000
Less: business loss of the year(100,000)
Reduced total income300,000
Less: basic allowance D26 exam (YA 2025/26): $132,000(145,000)
Net chargeable income155,000
Tax at progressive rates (standard-rate cap of 15% × 300,000 = 45,000 is higher, so not binding)9,700

Electing saves $15,650. The mechanism here is different from Illustration 1: without PA the loss is stranded in the profits tax computation and merely carried forward; PA lets it shelter current-year salary. IRD's 2025/26 version gives $8,520 against $24,560, a saving of $16,040.

Illustration 3 — The same property, but with a good salary: electing now costs money IRD pam37e Example 3, recomputed at 2026/27

As Illustration 1, but Miss Chan also earns $500,000 from employment.

Without electionHKD
Salaries tax on ($500,000 − $145,000) = $355,00042,350
Property tax (as Illustration 1)57,600
Total99,950
With election — Personal AssessmentHKD
Salary income500,000
Net assessable value384,000
Total income884,000
Less: mortgage interest(42,000)
Reduced total income842,000
Less: basic allowance D26 exam (YA 2025/26): $132,000(145,000)
Net chargeable income697,000
Tax at progressive rates (standard-rate cap 15% × 842,000 = 126,300, not binding)100,490

Electing costs $540 more ($100,490 against $99,950). Miss Chan is already at the 17% marginal rate on salary, so aggregating the property income taxes it at 17% rather than the 15% standard rate — and that outweighs the mortgage-interest deduction the election unlocks. This is the illustration to remember: the same taxpayer, the same property, the same mortgage, opposite answer, purely because of the other income. Under IRD's 2025/26 figures the election was similarly disadvantageous.

Illustration 4 — Married couple electing jointly, and how the tax is split IRD pam37e Example 4, recomputed at 2026/27

Mr Cheung's sole-proprietorship profit is assessed at $480,000. Mrs Cheung receives monthly rent of $20,000 from a mortgaged property and paid $72,000 of loan interest.

Business profits (Mr Cheung)480,000
Property, net assessable value (Mrs Cheung) ($20,000 × 12 × 80%)192,000
Less: mortgage interest(72,000)
Mrs Cheung's reduced total income120,000
Joint reduced total income600,000
Less: married person's allowance D26 exam (YA 2025/26): $264,000(290,000)
Net chargeable income310,000
Tax at progressive rates (standard-rate cap 15% × 600,000 = 90,000, not binding)34,700
Apportionment — in the ratio of each spouse's reduced total income
Mr Cheung: $34,700 × 480,000 / 600,00027,760
Mrs Cheung: $34,700 × 120,000 / 600,0006,940

Each spouse receives their own notice of assessment and demand for the apportioned amount. Note the apportionment base is reduced total income — Mrs Cheung's share is computed on $120,000 after her mortgage interest, not on the $192,000 NAV before it. IRD's 2025/26 version, using a $264,000 married person's allowance and the $3,000 reduction, gives $36,120 split $28,896 / $7,224.

Three further Personal Assessment election scenarios from Module 9 →

9. Common pitfalls

TrapWhat is actually right
Treating PA as a fourth head of chargeIt is a relief and an election. It changes how existing chargeable income is taxed; it never makes non-chargeable income chargeable.
Assuming PA always saves taxAbove roughly the point where the 17% marginal rate bites, it costs money — Illustration 3. Always compute both ways.
Recommending PA to a salary-only taxpayerThere is nothing to gain: progressive rates and allowances already apply.
Applying the standard-rate cap to net chargeable incomeThe cap is the standard rate on reduced total income, before personal allowances.
Deducting mortgage interest above the property's NAVCapped at that property's NAV. The excess lapses; it cannot create a loss.
Bringing in an offshore business lossOffshore profits were never chargeable, so the loss is not available.
Citing the mandatory joint electionOut of date. Separate election has been available since YA 2018/19. It remains mandatory to elect jointly only where the couple is already jointly assessed for Salaries Tax.
Relying on a spouse's residence to qualifyOnly for years up to 2017/18. From 2018/19 the elector must satisfy the residence test personally.
Apportioning joint tax by gross incomeThe ratio is each spouse's reduced total income.
Missing the withdrawal windowElection runs to 2 years after the year end; withdrawal is only 6 months from the assessment, and re-election afterwards needs the Commissioner's agreement.

10. Source Documents

Two source limitations, stated plainly Module 9 (4th ed.) is out of date on married couples. Its Chapter 6 describes the mandatory joint election and notes separate election as still awaiting LegCo approval. That approval happened — the Inland Revenue (Amendment) (No. 9) Ordinance 2018 brought separate election in from YA 2018/19. This page follows the current law, not the textbook.

Hong Kong Taxation and Tax Planning (22nd ed.) could not be used. It is a scanned PDF with no text layer and no OCR is available here, so nothing on this page is drawn from it. That limitation has since been worked around — the book can be read by rendering each page as an image, and the Computation Formats page does exactly that. This page has not yet been re-checked against the book’s own Personal Assessment chapter (Ch.46); worth doing.
Business — Stamp Duty

Stamp Duty

Stamp Duty Ordinance (Cap. 117) — a separate ordinance from the Inland Revenue Ordinance. Charged on share transfers, immovable property transactions, and leases.

印花稅說明印花稅以文書為課稅對象,涵蓋物業、股票、租約、BSD/SSD、關聯公司寬免及上訴程序。
Source note Stamp duty sits in the Stamp Duty Ordinance (Cap. 117), not Cap. 112 — the consolidated Cap. 117 text (current to 26 Feb 2026) is saved in Data/CAP117/. Section numbers below have been cross-checked directly against that text; where earlier SOIPN-based drafting of this page used outdated numbering or a superseded rate structure (notably the old flat-15% description of AVD Scale 1), it has been corrected below.

1. Overview

Stamp duty is a transaction tax, not an income tax — it is charged on specific categories of instruments (documents), not on profit. The three main heads for a Hong Kong company are: (1) Hong Kong stock transfers, (2) immovable property conveyances/agreements, and (3) leases. Hong Kong has no capital gains tax, estate duty, gift tax, or VAT — stamp duty is the main transaction-based levy filling that gap.

2026 amendment Stamp Duty (Amendment) Ordinance 2026 (gazetted 29 May 2026, effective retrospectively from 26 February 2026) revised the residential/non-residential AVD rate bands — figures below reflect the post-26-Feb-2026 rates per PwC (reviewed 22 Jul 2026). Verify against the gazetted schedule before relying on a specific banding for a transaction.

2. Share Transfers SDO s.19 (contract notes), First Schedule Head 2(1)

Ad valorem duty on transfer of Hong Kong stock0.2% of consideration or market value, whichever is higher (split 0.1% buyer / 0.1% seller, plus a small fixed contract note duty)

Contract notes are charged under s.19 (First Schedule Head 2(1)); s.21 prohibits stock being passed through without duty on the intervening step, s.22 covers consideration paid in stock/securities, and s.23 covers periodical-payment consideration. s.20 (formerly a related contract-note provision) has been repealed (33 of 2024 s.5) — do not cite it. Reliefs exist for stock borrowing/lending transactions (s.19(11) excludes a stock borrowing/return from the charge; s.19(12A) sets the borrower's return conditions; registration fee currently $270, must register within 30 days) and for intra-group ("associated companies") transfers under s.45 (§6 covers this in more detail) — see SOIPN 2.

New — RMB settlement of stamp duty on dual-counter stock The Stamp Duty (Amendment) (No. 2) Ordinance 2026 (Bill passed 8 July 2026, gazetted 17 July 2026) lets stamp duty on a transfer of dual-counter stock traded at the RMB counter be calculated and paid in Renminbi, so an investor settles the trade and the duty in the same currency at the same counter. The 0.2% rate is unchanged — this is a settlement-currency and administration change only. Commencement is on a day to be appointed by the Secretary for Financial Services and the Treasury, pending HKEX system readiness, so it is not yet in force.

2A. Conveyances & Agreements for Sale — Charging Mechanics SDO s.4, Part IIIA (ss.29A–29DV)

The general charge is s.4 ("Charging of, liability for, and recovery of stamp duty") read together with the First Schedule, which sets out each "Head of charge" and its rate. For immovable property, Part IIIA (originally ss.29A–29I, now expanded to ss.29A–29DV across 7 Divisions covering interpretation, conveyances, agreements for sale, refunds, and the AVD scale machinery) supplies the detailed mechanics — including the provisional/formal agreement stamping rules illustrated in DIPN/SOIPN 1 below.

3. Property Transfers — Ad Valorem Duty (AVD) First Schedule Head 1(1)/(1A); ss.29AI, 29AJ, 29AK

Correction vs. common assumption AVD Scale 1 is not a flat 15% on residential property. The flat-15% Scale 1 that applied from 5 Nov 2016 was superseded by a 2023 reform that made Scale 1 a graduated table matching Scale 2's bands (top rate 4.25%) — the only remaining difference is a new top band the Stamp Duty (Amendment) Ordinance 2026 added above ~$109.57M (see below). If your prior understanding was "flat 15% for non-HKPR/company buyers," that is now out of date except at the very top of the market.

AVD has three rate tables, all graduated (not flat), all sharing the same lower bands:

ScaleApplies toTop rate
Scale 1 (First Schedule Head 1(1)/(1A), default table — s.29AI)Residential property, buyer not qualifying for the Scale 2 concession (incl. companies, non-HKPRs)4.25% up to $100,000,000; a transitional band charging $4,250,000 + 30% of the excess from $100,000,000–$109,574,470; 6.5% flat above $109,574,470 (new top bands added by the Stamp Duty (Amendment) Ordinance 2026, s.14)
Scale 2 (s.29AJ concession)Hong Kong Permanent Resident buying their sole residential property, or a qualifying closely-related-person reassignment4.25% — unchanged by the 2026 amendment
Scale 3 (s.29AI(b) default for non-residential; also s.29AK for a car park bought alongside a Scale-2 residential purchase)Non-residential property4.25% — unchanged by the 2026 amendment

All three scales start at a flat $100 for low-value transactions and climb through the same intermediate bands (1.5% / 2.25% / 3% / 3.75%) before reaching their respective top rate. Duty is charged on consideration or market value, whichever is higher. "Closely related persons" (for Scale 2 eligibility and for the close-relative exemptions on BSD/SSD) is defined at s.29AD — broadly parent/spouse/child/sibling. Reliefs: replacement of a sole residential property (refund window), exchange/partition ("equality money" only), court orders, mortgagee sales, associated-company transfers under s.45 (§6) — see SOIPN 8, though note SOIPN 8 (Nov 2018) predates the 2023 Scale 1 reform and the 2026 amendment.

4. Buyer's Stamp Duty (BSD) & Special Stamp Duty (SSD) First Schedule Head 1(1AAB)/(1C) [BSD]; Head 1(1AA) [SSD]

Correction vs. common assumption There is no "Part IIIAA" or "Part IVA" for BSD/SSD in the current ordinance structure — Part IVA is actually the unrelated Unit Trusts/Open-ended Fund Companies part (ss.37A–41). BSD and SSD are instead defined as separate Heads of charge in the First Schedule, cross-referenced from Part IIIA.
DutyApplies toRate
Buyer's Stamp Duty (BSD) — Head 1(1AAB) conveyance / Head 1(1C) agreement for saleResidential property acquired by a non-HKPR (companies are always treated as non-HKPR); subject to ss.29C, 29CB, 29CC0% — reduced from 15% in stages (L.N. 148 of 2023; 3 of 2024 s.14; L.N. 26 of 2024; 8 of 2024 s.6)
Special Stamp Duty (SSD) — Head 1(1AA), Part 4 (property disposed of on/after 28 Feb 2024)Residential property resold within the holding-period window; subject to ss.29D, 29DA0% — reduced from up to 20% (L.N. 26 of 2024; 8 of 2024 s.6)
Note BSD and SSD remain fully defined in the First Schedule with their mechanics unchanged (liable party, timing, holding-period tiers for SSD) — only the rate was reduced to 0% as a market-support measure from 28 February 2024. Head 1(1AA)'s historical Parts 1–3 are preserved verbatim for legacy holding-period windows still being assessed (20 Nov 2010–27 Oct 2012 at 15/10/5%; 27 Oct 2012–25 Oct 2023 and 25 Oct 2023–28 Feb 2024, both at 20/15/10%) — relevant only if assessing an old disposal that hasn't yet been finalised. Both duties could in principle be reactivated at a non-zero rate by future amendment — see SOIPN 5 (SSD) and SOIPN 7 (BSD), noting both predate the current 0% rate and Head numbering nuances above.

5. Leases SDO Head 1(2)

Lease termDuty
Not defined or uncertain / ≤ 1 year0.25% of average annual rent (plus any premium, taxed as a sale)
Between 1 and 3 years0.5% of average annual rent
Over 3 years1% of average annual rent

A premium paid for a lease is chargeable as if it were a sale consideration, separately from the rent-based duty above — see the interaction with Property Tax/Profits Tax premium-spreading rules on the Property Tax page.

6. Reliefs SDO s.45; s.29AD

Associated bodies corporate relief (s.45) — relieves a conveyance from one associated body corporate to another from AVD, SSD, BSD, and HK-stock contract-note duty (it spans Heads 1(1), 1(1AA), 1(1AAB), 2(1) and 2(3)), where a ≥90% common-ownership test is met. A clawback applies under s.45(5A) if the ≥90% association ceases within 2 years of the relieved conveyance.

Bill before LegCo — do not apply yet · 法案仍待立法會審議 The Stamp Duty (Amendment) (No. 3) Bill 2026 (announced 29 Sep 2026, gazetted 2 Oct 2026, first reading 14 Oct 2026) would relax this relief: the association test would fall from 90% to 75%, association could be established through direct or indirect beneficial interests or voting rights rather than issued share capital alone, and the relief would extend to entities with no share capital — limited liability partnerships and companies limited by guarantee. The Bill proposes to apply to instruments executed on or after 25 February 2026.
The enacted test remains ≥90%. Quote 90% for any instrument being stamped now. The retrospective date is the part to watch: if enacted as drafted, transfers already executed since 25 Feb 2026 that met 75% but not 90% would become relievable. See IRD What's New §2.

Closely related persons (s.29AD) — defines the parent/spouse/child/sibling relationships that qualify for the Scale 2 AVD concession (§3) and are also picked up by the close-relative exemption notes applied to the BSD/SSD sub-heads (co-purchasers who are closely related are treated as "the same person" for ownership-counting purposes).

Proposed — newborn-family stamp duty concession, 2026 Policy Address (16 Sep 2026) A family with a child born in Hong Kong on or after 16 September 2026, where at least one parent is a Hong Kong permanent resident, would get a stamp duty waiver capped at HKD 20,000 on a residential property purchased in the window running from one year before to two years after the birth. To take effect on enactment of the amendment ordinance — not yet law, so do not apply it to a current transaction. Note it is a capped waiver, not a rate change: on any purchase where AVD exceeds HKD 20,000 the relief is a flat HKD 20,000.

7. Partnership Admission & Retirement

Where a partner is admitted to, or retires from, a partnership that holds Hong Kong stock or immovable property, the change in each partner's proportionate interest can itself be a chargeable "sale and purchase" of the underlying property/stock for stamp duty purposes (the incoming/continuing partners are treated as acquiring the outgoing/diluted partners' fractional interest). This is assessed using the same AVD/stock-transfer rules above, applied to the fractional interest that changes hands — always check partnership deeds and capital-account movements for a hidden stamp duty trigger whenever partners change.

8. Illustrations

10 worked illustrations back this page — SOIPN-sourced (agreement timing, AVD/SSD/BSD mechanics) plus Module 9 textbook examples. This is the topic needing the most correction: both source books predate the 2023 AVD Scale 1 reform and/or the 2024 BSD/SSD rate cut, so most headline rates in the older material are wrong — corrected figures are shown alongside the originals throughout.

Illustration — Current graduated Scale 1 vs. Scale 2 Corrected from Cap. 117 First Schedule, post-2026 amendment

A $13,000,000 residential property bought by a non-HKPR (or corporate) buyer with no Scale 2 concession available: Scale 1 is graduated exactly like Scale 2 at this value band (3.75%), giving $487,500 — not a flat-15% $1,950,000 as older material describes. The two scales only diverge for a single residential property with consideration above $100,000,000, where the 2026 amendment gives Scale 1 a new 6.5% flat top band that Scale 2 does not get.

9. Source Documents

Primary legislation: Stamp Duty Ordinance (Cap. 117), consolidated version current to 26 Feb 2026 — saved in Data/CAP117/. Sections referenced above: s.4, First Schedule Head 1(1)/(1A)/(1AA)/(1AAB)/(1C)/2(1), s.19, ss.19(11)/(12A)/(1E), ss.21–24, Part IIIA (ss.29A–29DV, incl. ss.29AD, 29AI, 29AJ, 29AK, 29C/29CB/29CC, 29D/29DA), s.45.

Note on this correction The SOIPNs below remain useful for mechanics and worked examples (timing rules, apportionment logic, relief conditions), but several were issued before the 2023 AVD Scale 1 reform and the 2026 amendment — cross-check any rate or Head/Part number they cite against the current Cap. 117 text in Data/CAP117/ rather than relying on the SOIPN's own numbering.

Core SOIPNs/DIPN for this page (download and save into Data/DIPN/Stamp-Duty/):

  • SOIPN 1 — Stamping of Agreements for Sale and Purchase of Immovable Property
  • SOIPN 2 — Relief for Stock Borrowing and Lending Transactions
  • SOIPN 5 — Special Stamp Duty (SSD)
  • SOIPN 7 — Buyer's Stamp Duty (BSD)
  • SOIPN 8 — Ad Valorem Stamp Duty (AVD)
  • DIPN 4 — Lease Premiums etc. (shared with Profits/Property Tax)

Cross-reference: PwC Worldwide Tax Summaries — Hong Kong SAR, Corporate/Individual — Other Taxes pages (saved copies in Data/PwC/).

Common — Depreciation & Allowances

Depreciation & Allowances

Inland Revenue Ordinance (Cap. 112), Part 6 & related provisions — capital allowances replace accounting depreciation for tax purposes; accounting depreciation itself is never deductible (IRO s.17(1)(c)).

折舊及免稅額整理工業/商業建築物免稅額、機械及設備、初期/每年免稅額、結餘課稅/免稅額及特定資產即時扣除。

1. Overview

Because capital expenditure and accounting depreciation are non-deductible under Profits Tax (s.17(1)(c)/(d)), Part 6 of the IRO substitutes a separate, statutory system of capital allowances for four categories of qualifying capital expenditure: (1) industrial buildings, (2) commercial buildings, (3) plant & machinery, and (4) a growing list of 100%/5-year write-off regimes for specific asset types (ss.16C–16L) that sit alongside, and interact with, Part 6.

Key mechanic — add-back and allowance in the same computation In every profits tax computation: add back accounting depreciation (non-deductible), then deduct the correct statutory allowance instead. The two numbers are almost never equal — this is the single most common adjustment in a Hong Kong tax computation.

2. Industrial & Commercial Buildings IRO ss.33A, 34, 36, 37

Building typeInitial allowanceAnnual allowanceBalancing allowance/charge
Industrial building or structure (mills, factories, docks, utility undertakings, qualifying storage/farming/R&D buildings)20% (1/5) of cost, year of first use4% (1/25) straight-line on costOn sale/lease termination/demolition — balancing charge capped at total allowances previously granted
Commercial building or structure (all other non-excluded buildings)None4% (1/25) straight-line on cost, from 1998/99Same balancing mechanism as industrial buildings, from 1998/99

"Industrial building or structure" is narrowly defined (DIPN 2) — it excludes dwellings, retail shops, showrooms, hotels, and offices. Where a building is used partly for a qualifying industrial purpose and partly not, a 10% de-minimis rule applies: if the non-qualifying use is no more than 10% of the whole, the building is treated as wholly industrial. On a sale, the buyer's future annual allowance is recalculated as the residue of expenditure after sale, spread over the remaining years to the building's 25th year from first use.

Historical note Before 1998/99, commercial buildings only qualified for a much smaller "rebuilding allowance" (0.75% pre-1990/91, then 2% from 1990/91–1997/98) rather than the modern 4% annual allowance — relevant only when tracing the residue of expenditure on a very old building still being written down today.

3. Plant & Machinery — Pooling System IRO ss.39B–39E

Since YA1980/81, plant and machinery of the same annual-allowance rate class is pooled together rather than tracked asset-by-asset (the old asset-by-asset method under ss.37–39 survives only for hire-purchase assets, mixed business/private-use assets, and a few other special cases).

Initial allowance60% of cost, given once on acquisition
Annual allowanceReducing-balance on the pool's "reducing value," at 10%, 20% or 30% depending on asset class (Board of Inland Revenue rates)
Common annual allowance rate classes (Appendix A(i), DIPN 7)
RateAsset examples
10%Air-conditioning plant, lifts, cables, ships
20%Furniture, fixtures, domestic/room air-conditioners — the general residual rate for unlisted items
30%Motor vehicles, computer/EDP equipment, textile/electronics manufacturing plant, tractors/bulldozers

Balancing allowances only arise when the trade/pool ceases altogether. Balancing charges can arise at any time disposal proceeds exceed the pool's reducing value, but are capped at the total allowances previously granted for that asset (you can never be charged more than you were originally allowed). Hire-purchase assets, and assets moved between private and business use, are excluded from pooling and calculated separately with notional allowance adjustments.

4. 100% / 5-Year Write-Off Regimes IRO ss.16C, 16F, 16G, 16H–16L

RegimeBasisTreatment
Technical education payments to approved institutionss.16CDeductible when paid
Refurbishment/renovation of non-domestic buildingss.16F5 equal annual instalments (20%/year)
Prescribed fixed assets — manufacturing plant, standalone computer hardware/software (excludes leased assets)s.16G100% one-off in year of payment
Environmental protection machinery & environment-friendly vehiclesss.16H, 16I100% one-off (from 2018/19; previously 5-year spread)
Environmental protection installations (buildings)ss.16J–16L100% one-off (from 2018/19; previously 5-year spread)

A taxpayer with unallowed instalments from pre-2018/19 environmental expenditure could elect under s.16I(3A) to accelerate the remaining instalments to a single 100% deduction in 2018/19 (see the DIPN 5 illustration below).

5. Patents, Know-How & Specified IP Rights IRO ss.16E, 16EA–16EC

AssetBasisTreatment
Patent rights / know-hows.16E100% one-off, year of purchase — no spreading
Specified IP Rights (copyright, registered trade marks/designs, plant variety rights, layout-design/topography rights, performer's economic rights)ss.16EA–16EC5 equal annual instalments (or shorter, to match remaining legal protection period)

Expenditure deductible under s.16E/16EA/16G/16I is excluded from Part 6 depreciation allowances — the regimes are mutually exclusive per asset, not cumulative. Anti-avoidance carve-outs deny the deduction for sale-and-license-back arrangements, purchases from associates, and IP used exclusively outside Hong Kong by another person under a leveraged licensing structure.

6. Illustrations

6 worked illustrations back this page — DIPN-sourced (industrial building sale, plant & machinery pooling, balancing charges, IP amortisation) plus a Module 9 textbook example spanning two years of pooling with disposals and additions.

Illustration — Industrial building sale: buyer/seller allowance split DIPN 2

A factory is built for $500,000 in February 1992. Initial allowance 20% = $100,000; annual allowance 4% = $20,000 in the first year, continuing for 3 more years, leaving a residue of expenditure of $320,000. The building is then sold for $420,000. The seller faces a balancing charge of $100,000 (sale price exceeds residue by $100,000, capped at allowances previously granted). The buyer's future annual allowance is recalculated as 1/21 (years remaining to the 25th year) × $420,000 = $20,000/year.

7. Computation Template

Net profit per accountsX
Add back: accounting depreciation (non-deductible, s.17(1)(c)/(d))X
Less: industrial/commercial buildings allowance (initial + annual, §2)(X)
Less: plant & machinery pool allowance (initial + annual by rate class, §3)(X)
Less: any 100%/5-year write-offs for qualifying assets (§4–5)(X)
Add: any balancing charge on disposal (capped at prior allowances granted)X
Less: any balancing allowance on cessation of a pool/trade(X)

8. Source Documents

CAP112 sections referenced above: ss.33A, 34, 36, 37 (buildings); ss.39B–39E (plant & machinery pooling); ss.16C, 16E, 16EA–16EC, 16F, 16G, 16H–16L (write-off regimes). Consolidated text: Data/CAP112/. Note: Part 6's body text was not fully machine-readable in the currently downloaded PDF extraction — the section numbers/rates above are cross-verified against DIPN 2/5/7/49 (which quote the Ordinance directly) rather than re-derived from a direct CAP112 grep; re-verify against a fresh Cap. 112 download if precision on a specific sub-clause is needed.

Core DIPNs for this page (download and save into Data/DIPN/Depreciation-Allowances/ — already saved during this build):

  • DIPN 2 — Industrial & Commercial Buildings Allowances
  • DIPN 5 — Technical Education, Refurbishment, Prescribed Fixed Assets, Environmental Protection
  • DIPN 7 — Machinery & Plant Depreciation Allowances
  • DIPN 49 — Patent Rights, Know-How and Specified IP Deductions

Cross-reference: PwC Worldwide Tax Summaries — Hong Kong SAR, Corporate — Deductions page (saved copies in Data/PwC/).

Common — IRD Administration

IRD Administration

Inland Revenue Ordinance (Cap. 112) — filing, assessment, objections, appeals, provisional tax and penalty mechanics that apply across Profits, Property and Salaries Tax.

稅務局行政涵蓋報稅、評稅、估計評稅、反對、上訴、暫繳稅緩繳、罰則、稅務調查,以及自動交換財務帳戶資料與加密資產申報。
Source note The section numbers on this page reflect the IRO's long-standing, stable administration framework, but this build's local CAP112 text extraction did not cleanly surface the Part 9–14 body text for direct verification (see §7). Cross-check exact wording against a fresh Cap. 112 download before citing a subsection in a formal position.

1. Overview

These provisions are common infrastructure across Profits Tax, Property Tax and Salaries Tax — a computation is only complete once you know how it gets filed, assessed, and (if needed) disputed or paid provisionally.

2. Returns & Filing IRO s.51

The Commissioner issues annual returns (profits tax, salaries tax, property tax, employer's return) which must be completed and filed by the stated due date — extensions are routinely available for corporate profits tax returns filed through a tax representative under the Block Extension Scheme. Every person carrying on a trade, profession or business must keep sufficient records (s.51C) for at least 7 years to enable profits/losses to be readily ascertained.

Practical note For a newly incorporated company, the first profits tax return is usually issued around 18 months after incorporation or commencement of business — but a company must still notify the Commissioner of chargeability (s.51(2)) within 4 months after the end of the basis period if no return has been issued, even where no return has yet been received.
Block Extension Scheme — 2025/26 returns, "D" code extended By circular letter of 14 July 2026, the Commissioner further extended the due date for 2025/26 profits tax returns with Accounting Date Code "D" (accounting date falling between 1 and 31 December 2025):
  • Paper filing: 17 August 2026 → 31 August 2026
  • Electronic filing: 17 September 2026 → 2 October 2026
The extension was granted to help businesses and practitioners adapt to new compliance requirements; the circular still urges representatives to file well before the extended date. Codes "N" and "M" were not changed by this circular. Source: Circular Letter to Tax Representatives — Block Extension Scheme for Lodgement of 2025/26 Tax Returns, 14 Jul 2026.
Business Tax Portal — new Responsible Person capacities (8 Jun 2026) IRD expanded the capacities in which a Responsible Person may register a business for the Business Tax Portal (BTP). Check the registration capacity before opening a BTP account for a client entity — an account opened in the wrong capacity has to be redone.

3. Assessment & Estimated Assessment IRO ss.59–60

The assessor assesses the return as filed, or — where no return is filed, or the assessor is not satisfied with a return — issues an estimated assessment based on the best information available. Estimated assessments are commonly issued precisely to protect the statutory time limit for assessment where a return is outstanding; they are not a final determination and are superseded once the actual figures are agreed (usually via an objection, §4).

Additional assessments may be raised within the statutory time limit (generally 6 years from the end of the relevant year of assessment, extended to 10 years in cases involving fraud or wilful default) where profits/income have been understated or under-assessed.

4. Objections & Appeals IRO s.64 (objections), s.66 (Board of Review), s.69 (case stated)

StageTime limitForum
Notice of objection1 month from the date of the assessmentCommissioner of Inland Revenue
Appeal against the Commissioner's determination1 month from the determinationBoard of Review
Case stated appeal on a point of law1 month from the Board's decisionCourt of First Instance, then Court of Appeal / Court of Final Appeal

An objection must state precisely the grounds of objection — a bare, unparticularised objection can be rejected as invalid. Tax under dispute is not automatically suspended; the taxpayer must separately apply to hold over payment of the tax in dispute (or the portion in dispute) pending resolution.

5. Provisional Tax & Holdover IRO ss.63A–63U, 71

Provisional profits tax, provisional salaries tax, and provisional property tax are each charged in advance, generally based on the immediately preceding year's assessable profits/income, and later set off against the final assessment for that year once it issues. A taxpayer may apply to hold over payment of the whole or part of provisional tax where, for example, the current year's profits/income are objectively likely to be significantly lower than the prior year's, or personal allowances have increased, or an objection is pending on the immediately preceding year's assessment.

Practical note Holdover applications have their own strict statutory deadlines (broadly, the later of 28 days before the provisional tax is due, or 14 days after the provisional tax notice is issued) — missing the window forfeits the holdover regardless of the merits.

6. Late Payment of Tax — Surcharge and Recovery IRO s.71; Part 12

The consequence almost every taxpayer actually meets, and the one most often confused with the penalties in §7. A surcharge under s.71 is not a penalty for an offence — it is automatic, needs no intent, no reasonable-excuse enquiry and no hearing. Miss the date and it is imposed.

WhenWhat happensProvision
The due date passes A 5% surcharge is imposed on the tax unpaid. Recovery action may begin immediately and without prior notice. s.71(5)
6 months after the due date A further 10% surcharge on the amount still unpaid — including the 5% already imposed. s.71(5A)
The 10% is charged on the tax plus the first surcharge — so it is not 15% On tax of $100,000 left unpaid for over six months:
Tax due100,000
Add: 5% surcharge — s.71(5)5,000
Amount unpaid after the due date105,000
Add: further 10% on $105,000 — s.71(5A)10,500
Total payable115,500
Total surcharge $15,500 — 15.5% of the original tax, not 15%. The second surcharge compounds on the first.

The instalment trap

Where a demand note is split into two instalments, missing the first makes the second immediately due, and the 5% is then charged on the whole outstanding balance — not just on the instalment that was missed.

Demand note of $100,000: first instalment $70,000, second $30,000
First instalment paid on time, second missed — 5% × $30,0001,500
First instalment missed — the second accelerates, so 5% × $100,0005,000
Cost of missing the earlier date rather than the later one3,500

Left unpaid for six months, that same note reaches $115,500.

Recovery of tax in default IRO Part 12

IRD does not wait for the six-month mark before acting. Its own notice states that other than imposing the 5% surcharge it "will also immediately commence other recovery actions without prior notice":

ActionWhat it means in practice
Recovery notice to a third party
s.76
Served on anyone who owes or holds money for the defaulter — employer, bank, tenant, debtor, customer. That person must pay the money to IRD instead, and is discharged to the extent they do. This is why a tax default can become visible to an employer or banker.
Civil proceedings
s.75
Tax in default is recoverable as a civil debt in the District Court. A judgment carries the usual consequences, including costs and interest on the judgment debt.
Departure prevention order
s.77
The Commissioner may apply to a District Judge for a direction stopping a defaulter from leaving Hong Kong until the tax is paid or security given.
Joint and several liability
property tax co-owners
Co-owners are liable jointly and severally: IRD may pursue any one of them for the whole amount, not merely their share. Once one pays in full, recovery against the others stops. Tax is never collected twice, and any overpayment is refunded.
Applying to pay by instalments does not stop the surcharge A taxpayer in genuine financial difficulty may apply to settle by instalments. But IRD is explicit that even where the application is approved, surcharges are still imposed on tax remaining unpaid after the due date. An instalment arrangement buys time and heads off recovery action; it is not a waiver. Conditional waiver schemes have been offered in particular years as a relief measure, but they are exceptional and year-specific — never assume one applies.
Keep the two regimes apart — this is the distinction to have straight
Surcharge, s.71Penalty, ss.80 / 82A / 82
Triggered byPaying lateFailing to file or notify, filing an incorrect return, or evading tax
Fault requiredNone — automatic on the dateAbsence of reasonable excuse; for s.82, wilful intent
Amount5%, then a further 10% on the totalUp to treble the tax undercharged, plus a fine and, under s.82, imprisonment
Who imposes itThe Commissioner, administrativelyThe Commissioner (s.82A) or a court (ss.80, 82)
A taxpayer who files a correct return on time but pays late faces the surcharge only. One who files late and pays late faces both.

Source: IRD, Pay Tax On Time to Avoid Penalty and Recovery Actions, and GovHK Consequences of Not Paying Tax On Time and Recovering Tax in Default.

7. Penalties IRO ss.80, 82, 82A

ContraventionConsequence
Failure to file a return, or filing late, without reasonable excuseSummary conviction fine and/or additional tax (s.80)
Making an incorrect return, or omitting income, without reasonable excuseAdditional tax up to treble the tax undercharged (s.82A) — an administrative penalty assessed by the Commissioner, distinct from criminal prosecution
Wilfully with intent to evade, or assisting another to evade, taxCriminal prosecution (s.82) — fine up to treble the tax undercharged plus imprisonment up to 3 years

Additional tax under s.82A is an administrative sanction (no need to prove criminal intent) and can be settled by way of a compound penalty offer from the Commissioner in less serious cases — this is the mechanism most commonly encountered in routine tax computation corrections and voluntary disclosures.

8. Double Taxation Relief & Tax Clearance IRO ss.49, 50, 51D

Where Hong Kong has a comprehensive double taxation agreement (CDTA) with another jurisdiction, s.50 provides a tax credit for foreign tax paid on income also taxed in Hong Kong (interacting with the s.16(1)(c)/(2J) deduction restriction on the Profits Tax page). Employers must comply with tax clearance obligations (s.51D) before an employee who is about to leave Hong Kong permanently, or for a substantial period, ceases employment — including withholding final payments until IRD confirms clearance or a specified period has elapsed.

CDTA network (as at 24 September 2026): Hong Kong signed its 60th comprehensive double taxation agreement with Slovenia on 4 September 2026, following Nigeria (13 July 2026) and Cyprus (12 June 2026). Each enters into force only after both sides complete ratification — check the IRD CDTA list for the in-force date before claiming treaty relief.

9. Automatic Exchange of Information & Crypto-Asset Reporting IRO Part 8A

Two separate 2026 measures extend Hong Kong's information-exchange obligations, and both change what a reporting financial institution has to collect:

Policy watch The Advisory Committee on Tax Policy held its first meeting on 29 June 2026 — the standing forum now shaping medium-term HK tax policy. IRD also responded to an Ombudsman direct investigation report on 31 August 2026, and published its Annual Report on Performance Pledge 2025-26 on 9 July 2026 (useful for expected turnaround times on objections and refunds).
Fraud alerts — tell clients IRD issued fraudulent-email alerts on 6 July, 22 July, 4 September and 15 September 2026 (fake prosecution notices, fake tax audit notices, and phishing for email passwords), plus a 25 August 2026 warning not to download the eTAX Mobile Application from unofficial channels. IRD does not request passwords or payment by email link.

10. Source Documents

CAP112 Parts referenced above: Part 9 (Returns and Information), Part 10/10A–10C (Assessment, Provisional Tax), Part 11 (Objections and Appeals), Part 12 (Payment and Recovery), Part 14 (Penalties). Consolidated text: Data/CAP112/. As noted at the top of this page, re-verify exact subsection wording against a fresh, fully-extractable copy of Cap. 112 before relying on a specific citation.

Recommended additions to Data/IRD-Administration/: IRD's "A Guide on the Objection and Appeal Procedures under the Inland Revenue Ordinance," and the annual Block Extension Scheme circular (both published on ird.gov.hk).

Business — Profits Tax

Profits Tax Return Guide

Box-by-box walkthrough of BIR51 (current revision 4/2025) — bridging "what the law says" (the Profits Tax and Depreciation & Allowances pages) with "what you actually type into the form." Use the Box Finder to search by keyword instead of reading start to end.

利得稅報稅表指南把 BIR51/52/54 的欄位與稅務計算邏輯連接,說明哪些資料要填在報稅表,哪些屬於另附稅務計算。
Key structural point BIR51 does not contain a line-by-line add-back/deduction schedule as boxed items. Part 1 only captures the three final results — Assessable Profits, Adjusted Loss, Loss brought forward (boxes 1–3). The actual add-backs and deductions (depreciation, capital expenditure, non-deductible items, etc.) are worked out separately in a "tax computation with supporting schedules" that you attach as a Supporting Document — it is not printed on the form itself. That computation is exactly what the Computation Template on the Profits Tax page walks through.

1. Which Form Applies

FormWho files it
BIR51Corporations — the primary form for HK incorporated companies, and the focus of this guide.
BIR52Persons other than corporations — sole proprietorships, partnerships, limited partnership funds, bodies of persons. See §9 below for how it differs from BIR51.
BIR54Not a second "persons other than corporations" form — filed by a Hong Kong resident payer/agent to report a non-resident's HK-sourced profits under ss.20A/20B. See §10 below.

All three are issued annually and must be filed within the deadline stated on the Notice to File (IRC1952 for corporations, IRC1953 for others) — typically extended under the Block Extension Scheme where a tax representative is on record. Since 1 April 2023, all supplementary forms (S1–S22) must be filed electronically via www.ird.gov.hk/e_pfr.

2. Part 1 — Statement of Assessable Profits or Adjusted Loss

BoxLabelMaps to
1Assessable Profits (before loss brought forward)The bottom line of your computation — see the Computation Template.
2Adjusted Loss (before loss brought forward)Fill instead of box 1 if the year produced a loss.
3Loss brought forward from prior years.19C carry-forward — see Basis Period & Loss Relief.

3. Parts 2–3 — Tax Liability, Rate Election & Specified Matters

Part 2 computes Tax Payable/Repayable (IRD-computed, no entry box) and asks:

Box 4Chargeable at two-tiered rates? — the two-tiered rate election. If Yes, upload Form S1 (Part 9, box 42).

Part 3 is a run of Yes/No disclosure questions (boxes 5–15) covering non-resident IP payments (s.15(1)), fund/carried-interest deeming provisions, short/medium-term debt instruments, DTA relief claims, advance rulings, alternative bond schemes, regulatory capital securities, permanent-establishment status, and the s.51AAB e-filing mandate. None of these require a computed figure — they flag which supplementary forms and disclosures apply.

4. Parts 4–8 — Company Details & General Matters

Parts 4–6 are administrative: principal business activity + HSIC code (box 16), return-language preference, and an optional authorized representative section.

Part 7 (General Matters, boxes 17–36) is the section most likely to interact with your tax computation:

BoxWhat it asks
17–19Whether accounts are audited by law, by a HK practice unit, and the signing CPA's practising certificate number.
20Basis period From/To — feeds the basis-period rules (s.18/18C).
21–24Commencement/cessation of business, and what happened to the business/assets on cessation.
25Election to align financial-instrument tax treatment with accounting treatment (ss.18I–18L) — see the DIPN 42 illustration.
26–27Foreign-currency financial statements; private company status.
28Change in shareholders during the basis period — relevant to loss-carry-forward anti-avoidance (DIPN 15).
29Party to a court-free amalgamation (s.680/681 Companies Ordinance) — see DIPN 63.
30Contract/import processing arrangement in the Chinese Mainland — the 50:50 apportionment convention (DIPN 21).
31–36Insurance RBC-regime transition, family-owned SPE/single-family-office status.

Part 8 (Transactions For/With Non-Residents, boxes 37–41) covers acting as an agent for a non-resident, IP value-creation contributions, and HK$ amounts for hire charges/professional fees paid to non-residents.

5. Part 9 — Supplementary Forms Uploaded (S1–S22)

A checkbox per supplementary form, boxes 42–63 (BIR51). Every S-form must be e-filed via www.ird.gov.hk/e_pfr, signed, and submitted with a Control List.

FormCovers
S1Two-tiered profits tax rates election
S2Transfer pricing and international tax obligations
S3Expenditure on research & development (DIPN 55)
S4Expenditure on energy efficient building installation
S5Ship-owner
S6Professional reinsurer
S7Authorized captive insurer
S8Qualifying corporate treasury centre (DIPN 52)
S9Qualifying aircraft lessor (DIPN 54)
S10Qualifying aircraft leasing manager
S11Qualifying ship lessor (DIPN 62)
S12Qualifying ship leasing manager
S13Specified insurer
S14Licensed insurance broker company
S15Persons deriving eligible carried interest
S16Qualifying ship agent
S17Qualifying ship manager
S18Qualifying ship broker
S19Taxation on specified foreign-sourced income — the FSIE regime
S20Tax concessions for family-owned investment holding vehicle
S21Tax certainty enhancement scheme for onshore gain on disposal of equity interests
S22Tax concessions for intellectual property income — the Patent Box concession

BIR52 only lists 10 of these (S1, S2, S3, S4, S5, S15, S19, S20, S21, S22) — the shipping/aircraft-leasing/insurance/treasury-centre forms are corporation-only concessions. BIR54 only references S1 and S5.

6. Part 10 — Tax Data (boxes 64–93)

HK$ amount fields (enter "0" if nil) for offshore profits excluded from Part 1, capital-asset sale profits, exempt interest/securities income, and — most relevant to a typical computation — the deduction items that mirror the Depreciation & Allowances page's write-off regimes:

BoxDeduction
74Approved charitable donations
75Building refurbishment expenditure (s.16F)
76Computer hardware/software expenditure (s.16G)
77Prescribed manufacturing machinery/plant expenditure (s.16G)
78–80Environmental protection machinery / installation / environment-friendly vehicles (ss.16H–16L)
81–82Patent rights / rights to know-how (s.16E)
83–88Specified IP Rights — copyrights, performer's rights, layout-design, plant variety rights, registered designs, registered trade marks (ss.16EA–16EC)
89–91DTA relief / unilateral foreign tax credit (s.50 vs s.16(1)(c) — see the DIPN 28 illustration)
92Interest to non-HK associated corporations, intra-group financing business
93Leased premises reinstatement costs

All of boxes 75–88 correspond directly to write-off regimes on the Depreciation & Allowances page — if you've already worked out that page's computation template, these boxes are just transcribing the same figures.

7. Part 11 — Depreciation Allowances Claimed (boxes 94–104)

CategoryInitialAnnualBalancing AllowanceBalancing Charge
Industrial Building94959697
Commercial Building—9899100
Machinery or Plant101102103104

This is a direct transcription target for the Depreciation & Allowances computation template — work out the allowance there, then drop the totals into these boxes.

8. Parts 12–13 — Financial Data & Declaration

Part 12 (boxes 105–127) asks for headline financial-statement figures — gross income, turnover, inventories, gross profit/loss, dividend/interest income and expense, remuneration, commission, IP payments, management/consultancy fees, bad debts, net profit/loss per account, receivables/payables, issued share capital, and total assets. This is IRD cross-checking your return against the shape of your accounts, not a separate computation.

Part 13 (boxes 128–129) is the declaration — tick exactly one: box 128 for a Secretary/Manager/Director/Investment Manager/Provisional Liquidator/Liquidator declaring the return is complete and accurate, or box 129 for a Service Provider declaring it was prepared per the taxpayer's confirmed instructions (IR1476).

9. BIR52 — How It Differs from BIR51

Structurally parallel but shorter (129 boxes → ~111) and reorganized. The headline differences:

  • Part 1 extras (boxes 4–5): whether the proprietor/spouse/partner received emoluments or interest on capital from the business — such payments are non-deductible under s.17(2), and box 5 confirms the tax computation adjusts for it. The two-tiered rate election is box 6 here, not box 4.
  • Part 6 is entirely new: "Personal Particulars of Proprietor or Partners and Allocation of Profits/Loss and Claim for Deduction of Mandatory Contributions" (boxes 18–37) — per-partner HKID/BR number, profit/loss sharing ratio, a Personal Assessment election flag (the actual election is made on the individual's own BIR60, not here), allocated Assessable Profits/Adjusted Loss, and MPF contributions claimed. The allocation total must equal Part 1's box 1/2. See the Personal Assessment section.
  • Part 7 drops the corporation-only items (RBC regime, Companies Ordinance amalgamation, private-company/shareholder-change questions) and adds business-specific ones: cessation by death of the proprietor, and property purchase for building allowance purposes.
  • Part 9 lists only 10 supplementary forms (the corporation-only concessions S6–S14, S16–S18 don't apply).
  • Part 10 swaps BIR51's "interest to non-HK associated corporations" box for a "mandatory MPF contributions for proprietor/partners" deduction.
  • No separate depreciation-allowances Part — Financial Data shifts one part earlier, and the corporation-only "share-based payments"/"issued share capital" fields are dropped.
  • Declaration title varies by entity type: sole proprietorship → "person"; partnership → "precedent partner"; limited partnership fund → "general partner" / "investment manager"; body of persons → "principal officer"; no resident proprietor/partner → "agent"/"manager"; deceased estate → "executor."

10. BIR54 — What It Actually Is

Common misconception, corrected BIR54 is not a second "persons other than corporations" return. Its actual title is "Profits Tax Return — In Respect of Non-Resident Persons." It is filed under ss.20A/20B by the Hong Kong resident payer or agent, in the non-resident's own name, to report that non-resident's Hong Kong-sourced trade/business profits — most commonly royalty/IP payments, or income received via a Hong Kong agent. It's bilingual (Chinese/English) and far shorter than BIR51/52 (~22 boxes).

Key sections: a two-tiered rate election made on behalf of the non-resident (box 3, with the same connected-entity disclosure logic as BIR51/S1); an IP use/assignment block (boxes 11–17) determining whether the deemed-profit computation under s.21A(1)(a) applies 100% or 30% of the royalty receipt as assessable profit; a section on the agent's role in Hong Kong; and a reciprocal shipowner exemption block (boxes 18–20, s.23B(4A)) for non-resident shipowners.

11. Source Documents

Forms (revision 4/2025) saved in Data/Forms/: BIR51, BIR52, BIR54, their respective Notes and Instructions, and the Notice to File forms (IRC1952 for corporations, IRC1953 for others).

  • BIR51 — Profits Tax Return (Corporations)
  • BIR51 Notes and Instructions
  • BIR52 — Profits Tax Return (Persons Other Than Corporations)
  • BIR52 Notes and Instructions
  • BIR54 — Profits Tax Return (Non-Resident Persons)
  • BIR54 Notes and Instructions
  • IRC1952 / IRC1953 — Notice to File

Downloaded from ird.gov.hk (index pages: eng/tax/bus_returnspecimen.htm, eng/tax/bus_cpt.htm). Note G Part 1(2) of the BIR51 Notes lists the standard tax-computation add-back/deduction items in full — not yet fully extracted into this guide; ask Claude for a follow-up pass if your team needs that level of detail transcribed too.

← Back to the Profits Tax Return Guide

Application tool

Profits Tax Return — Box Finder

Search BIR51 (corporations), BIR52 (persons other than corporations), and BIR54 (non-resident persons) by keyword to find which box a figure or disclosure goes in. This is a lookup aid over the current (4/2025) forms — not a tax calculator; it does not compute figures for you.

利得稅報稅表欄位搜尋用關鍵字尋找 BIR51、BIR52、BIR54 欄位,適合在準備報稅表或溫習 supplementary forms 時使用。
How to use Type a keyword (e.g. "depreciation", "two-tiered", "loss brought forward", "audited accounts", "MPF", "non-resident"). Filter by form if you already know which return you're working on. Where a box ties to a concept covered elsewhere in the hub, a "View section" link is shown.

FormBoxPartLabelNote
Scope & limits Box numbers and labels are drawn from the current forms as published on ird.gov.hk (revision 4/2025) — verify against a freshly downloaded form before relying on a box number for an actual filing, since IRD periodically renumbers when new disclosure items are added. This tool does not replace the "tax computation with supporting schedules" you must prepare and attach separately — Part 1's boxes 1–3 are only the final results of that computation, not the computation itself.

← Back to Profits Tax rules

Business — Profits Tax

Profits Tax — Worked Illustrations

Every worked example backing the Profits Tax page, in one place — drawn from IRD's DIPNs and from Module 9: Principles of Taxation (4th ed.). Figures are cross-checked against current law; any outdated textbook figure is corrected and flagged.

利得稅例題以改寫例題展示來源地、資本/收益性質、壞帳、知識產權、虧損及兩級制計算等常見考點。
Sources & attribution Two kinds of source, labelled inline on every illustration. DIPN/SOIPN examples are paraphrased from IRD's own published notes — never reproduced verbatim; each links to the DIPN Index, where the Official column points to IRD's authoritative PDF. Textbook examples are adapted from Module 9: Principles of Taxation (4th ed.), a professional qualification manual: the fact patterns are restated in our own words, the numbers are independently recomputed against current law, and where the book's figure is now stale it is shown alongside the corrected one. No textbook text is reproduced. These are study notes — see the licence: readable and linkable, not licensed for redistribution.

A. From IRD DIPNs

Illustration — Lease premium: Profits Tax vs Property Tax interaction DIPN 4

Company H grants a 6-year lease of its property for a premium of $1,200,000, paid up front. As a person carrying on a property-dealing/letting business, the premium is a revenue receipt taxable under Profits Tax — s.15C spreads it evenly over the lease term, so 1/6 = $200,000 is assessed each year for 6 years. Separately, s.5B(4) deems the premium payable in equal monthly instalments for Property Tax purposes but capped at 3 years, so 1/3 = $400,000 is assessed for Property Tax in each of Years 1–3 only.

YearProperty Tax paid
($400,000 × 80% × 16%)
Profits Tax
($200,000 × 17.5%)
Net position
1–3 (each)$51,200$35,000Refund of $16,200 (Property Tax set off against Profits Tax under s.25)
4–6 (each)—$35,000$35,000 payable

Grand total tax over 6 years = $210,000, i.e. exactly 17.5% of the $1,200,000 premium (the historical standard rate used in the DIPN's example year) — the set-off mechanism ensures the premium is not taxed twice under both heads.

Illustration — Interest deduction restricted by a tax-free secured deposit DIPN 13A

Taxpayer F borrows $1,000,000 at 5% interest, secured by a $1,000,000 deposit earning tax-exempt interest at 4%. Because the loan is secured on a deposit generating tax-free income, s.16(2A)/(2B) restrict the deduction: the $40,000 tax-free interest earned reduces the otherwise-deductible $50,000 loan interest, leaving only $10,000 deductible.

Illustration — Service company "Type II" management fee cap DIPN 24

A professional firm pays $4,000,000 in management fees to a related service company whose actual attributable cost of providing those services is $3,000,000. The deduction is capped at cost plus a 12.5% mark-up: $3,000,000 × 112.5% = $3,375,000. The $625,000 excess is added back, increasing assessable profits from $1,000,000 (per accounts) to $1,625,000.

Illustration — Foreign tax deductible only where no DTA credit is available DIPN 28

Bank-HK pays income tax on interest income in Jurisdiction F. If Hong Kong has no double tax agreement with Jurisdiction F, the foreign tax is deductible under s.16(1)(c). If Hong Kong does have a DTA with Jurisdiction F, s.16(2J) denies the deduction — Bank-HK must instead claim a tax credit under s.50, since double relief (deduction plus credit) is not permitted.

Illustration — Hong Kong bank deposit interest exemption straddling the exemption date DIPN 34

A taxpayer has $10,000,000 trading profits plus $4,000,000 of local bank deposit interest, of which $1,000,000 accrued before 22 June 1998 (the exemption's effective date) and $3,000,000 accrued after. Only the pre-exemption $1,000,000 is taxable; total 1998/99 assessable profits = $11,000,000 rather than $14,000,000.

Illustration — Prepaid expenses follow accounting treatment, not cash timing DIPN 40, following CIR v Secan

Following the Secan case, a full cash prepayment (e.g. 3 years' rent or insurance paid up front) is no longer deductible in full in the year of payment if the applicable accounting standard requires it to be amortised over the period it relates to — the tax deduction now follows the accounting/matching treatment, reversing the Department's older cash-basis practice.

B. From Module 9: Principles of Taxation (4th ed.)

Adapted from a professional taxation qualification manual. Facts are paraphrased, not reproduced verbatim; every figure has been checked against current Hong Kong tax law and corrected where the textbook is outdated (noted per illustration).

Illustration — Basis period on commencement: first accounts cover 18 months Module 9, Ch.3 §3.9.2 — s.18C(1)(b)

A company commences business on 1 July 2018 and adopts a 31 December accounting date, but its first set of accounts is not closed until 31 December 2019 — an 18-month period. Adjusted profits: $90,000 for the 18 months to 31 Dec 2019, then $68,000 for the 12 months to 31 Dec 2020.

Where the first accounting period exceeds 12 months, s.18C(1)(b) gives the Commissioner discretion to take the second year of assessment as the 12 months counted back from the end of the first accounting period, with the commencement year taking the remaining stub — both by time-apportioning the 18-month profit.

Year of assessmentBasis periodAssessable profitsBasis
Commencement year1/7/2018 – 31/12/2018 (6 mo.)$30,000 (= $90,000 × 6/18)s.18C(1)(b)
Following year1/1/2019 – 31/12/2019 (12 mo.)$60,000 (= $90,000 × 12/18)s.18B(2)
Third year1/1/2020 – 31/12/2020 (12 mo.)$68,000s.18B(2)

Check: $30,000 + $60,000 = $90,000 — the full 18-month profit is accounted for exactly once. No tax rate is involved in this mechanic, so no currency correction was needed.

Illustration — Retirement scheme contribution cap (s.17(1)(h)) Module 9, Ch.3 §3.5.4

An employee earns an annual salary of $100,000. The employer makes an ordinary annual contribution to a recognised retirement scheme equal to 20% of salary, i.e. $20,000.

s.17(1)(h) disallows the deduction of ordinary retirement-scheme contributions to the extent they exceed 15% of the employee's total emoluments: cap = 15% × $100,000 = $15,000 deductible; the remaining $5,000 is non-deductible.

The 15% cap is unchanged in current law — no correction needed.

Illustration — Loss relief: carry-forward vs. surrender on change of trade Module 9, Ch.3 §3.11 — s.19C

Part A — corporation, multi-year carry-forward: a company realises losses of $25M (2016/17) and $75M (2017/18), giving $100M carried forward. It then realises a profit of $80M in 2018/19.

Accumulated losses available$100,000,000
Less: set off against 2018/19 profit($80,000,000)
Assessable profit after set-offNil
Unrelieved loss carried forward$20,000,000

Part B — sole proprietor, same trade vs. changed trade: a sole proprietor has an unrelieved loss of $1,000,000 brought forward from a wine-distribution trade.

ScenarioResult
Continues the same wine trade, earning $1,200,000 in the current year$1,200,000 − $1,000,000 loss b/f = $200,000 taxable
Ceases the wine trade and starts an unrelated fruit-trading business, earning $500,000Loss is tied to the ceased trade and is surrendered — full $500,000 taxable, no relief

Losses only carry forward against future profits of the same source (s.19C) — changing to an unrelated trade forfeits the loss. No tax rate is involved in either part, so no correction was needed.

Illustration — Secured loan test: interest deduction restricted by a tax-free deposit Module 9, Ch.3 §3.5.3.8 — s.16(2A), adapted from DIPN 13A

A taxpayer borrows $1,000,000 from a bank at 5% p.a. ($50,000 interest) for general business use, secured by an overseas deposit earning tax-free interest. The allowable deduction depends on how the security is structured:

CaseSecurityTax-free interest earnedDeduction reduced byInterest allowed
1Deposit $1,000,000 only$40,000$40,000 (full match)$10,000
2Deposit $500,000 + shares $500,000$20,000 (deposit only)$20,000 (shares ignored — not a deposit)$30,000
3Deposit $2,000,000 (exceeds loan)$80,000Pro-rated: $1,000,000/$2,000,000 × $80,000 = $40,000$10,000
4Deposit $1,000,000 + shares $500,000$40,000 (deposit only)Pro-rated by security mix: $1,000,000/$1,500,000 × $40,000 = $26,667$23,333

Only deposits/loans generating tax-free interest trigger this restriction — other security (shares, property, guarantees) is ignored for this test. No profits tax rate is involved, so no correction was needed.

Illustration — Interest flow-back test: debenture interest paid to an untaxed associate Module 9, Ch.3 §3.5.3.8 — s.16(2C), adapted from DIPN 13A

A Hong Kong company issues $10,000,000 of debentures to fund its HK trading business, paying $1,000,000 total interest for the year. $8,000,000 of the debentures is held all year by its overseas subsidiary, an associate not taxed in Hong Kong on the interest it receives.

Proportion held by the untaxed associate$8,000,000 / $10,000,000 = 8/10
Interest disallowed (flows back untaxed)$1,000,000 × 8/10 = $800,000
Allowable interest deduction$200,000

If the associate held the debentures for only 6 of the 12 months, the disallowance is further time-apportioned: $800,000 × 6/12 = $400,000 disallowed instead.

Exception: no restriction applies if the associate is a market maker holding the debentures in the ordinary course of its business (s.16(2G)). No profits tax rate is involved, so no correction was needed.

Note A plant & machinery pooling illustration and a full two-tier-rate computation exercise were also reviewed from this chapter but are presented on the Depreciation & Allowances illustrations page instead, where they fit topically.

← Back to Salaries Tax rules

Individual — Salaries Tax

Salaries Tax — Worked Illustrations

Every worked example backing the Salaries Tax page — drawn from IRD's DIPNs and from Module 9: Principles of Taxation (4th ed.). Figures are cross-checked against current YA 2026/27 allowances/rates; any outdated textbook figure is corrected and flagged.

薪俸稅例題以服務地點、僱傭關係、福利、股份獎勵及個人入息課稅情境強化考試判斷。
Sources & attribution Two kinds of source, labelled inline on every illustration. DIPN/SOIPN examples are paraphrased from IRD's own published notes — never reproduced verbatim; each links to the DIPN Index, where the Official column points to IRD's authoritative PDF. Textbook examples are adapted from Module 9: Principles of Taxation (4th ed.), a professional qualification manual: the fact patterns are restated in our own words, the numbers are independently recomputed against current law, and where the book's figure is now stale it is shown alongside the corrected one. No textbook text is reproduced. These are study notes — see the licence: readable and linkable, not licensed for redistribution.

A. From IRD DIPNs

Illustration — Joint assessment saves tax vs separate taxation DIPN 18

Mr A earns $680,000, Mrs A earns $100,000. Taxed separately, their combined liability is $23,030. Electing joint assessment under s.10(2) — pooling income and allowances — reduces the combined liability to $17,505, because Mrs A's unabsorbed allowances/deductions offset Mr A's higher-rate income.

Illustration — Home loan interest apportionment by ownership type DIPN 35

Mr C is sole owner, pays $120,000 interest — allowable deduction capped at $100,000. Mr & Mrs D are joint tenants, pay $100,000 total interest between them — each gets $50,000. Mr E (1/4 share) and Mr F (3/4 share) are tenants in common on a $100,000 interest bill — Mr E gets $25,000, Mr F gets $75,000 (apportioned strictly by ownership share, not by who actually paid).

Illustration — VHIS premium cap applied per insured person DIPN 56

Mr J pays VHIS premiums for himself ($5,000), spouse ($4,000), grandmother ($16,000), father ($12,000), mother ($11,000), son ($3,000) — total $51,000 paid. Because the cap is HKD 8,000 per insured person, the grandmother/father/mother claims are each capped at $8,000: allowable deduction = $5,000 + $4,000 + ($8,000 × 3) + $3,000 = $36,000. The $15,000 excess simply lapses — no carry-forward.

Illustration — Charitable donation cap at 35% of reduced assessable income DIPN 37

Mr A has salary $500,000, deductible expenses $10,000 (reduced assessable income $490,000), and made donations of $210,000. Since $210,000 exceeds 35% of $490,000, the deduction is capped at $490,000 × 35% = $171,500 — the remaining $38,500 of donations gives no further tax benefit.

Illustration — Share option gain apportioned by vesting days in Hong Kong DIPN 38

An employee's share option has a 730-day vesting period, of which 292 days were spent working in Hong Kong. At exercise, only 292/730 = 40% of the gain is assessable to Hong Kong salaries tax — the remainder relates to non-Hong Kong employment and falls outside the charge.

B. From Module 9: Principles of Taxation (4th ed.)

Adapted from a professional taxation qualification manual. Facts are paraphrased, not reproduced verbatim; every allowance/rate figure has been checked against current Hong Kong tax law and corrected where the textbook was using a stale amount (noted per illustration).

Illustration — The 60-day rule: two early departures tip the count over the line Module 9, Ch.4 §4.1 — s.8(1B)

An employee holds a Hong Kong employment contract but works full-time in Mainland China, returning to Hong Kong only periodically. His visits (quarterly meetings plus connecting travel) total 59 "ordinary" days for the year. On two occasions, however, he leaves Hong Kong very early in the morning to connect onward (once via Osaka, once via London) rather than flying straight back to China. Under the counting convention, both the day of arrival and the day of departure count as a full day each — even for a same-day transit.

Days in HK from ordinary visits59
Extra day — early departure via Osaka+1
Extra day — early departure via London+1
Total days in Hong Kong61

61 > 60, so the s.8(1B) exemption fails entirely — his full Hong Kong-employment income becomes chargeable, even though he worked in China almost all year. It's a hard cliff-edge test on days present, not days worked, and transit days count in full. No allowance/rate figures involved, so no correction was needed.

Illustration — Rent-free housing benefit: the "rental value" method Module 9, Ch.4 §4.2 — s.9(2)

An employee on a $600,000 salary gets a company-leased apartment rent-free; the employer also reimburses $16,800 of medical insurance (a taxable perquisite). Rental value = 10% of (salary + taxable perquisites) for a self-contained flat/house.

Salary + taxable perquisite$616,800
Rental value (10% × $616,800)$61,680

Contrast — two staff sharing one room in a company flat (boarding-house-type arrangement, not a self-contained flat) use the lower 4% rate instead of 10%:

EmployeeIncomeRental value (4%)
Staff A$150,000$6,000
Staff B$120,000$4,800

Rate scale (s.9(2)): flat/house = 10% of net employment income; hotel/hostel/boarding-house of ≤2 rooms = 8%; ≤1 room / shared-room = 4%. These percentages sit in the Ordinance itself (not an annually-adjusted allowance) — no update needed, but worth a one-line confirmation against IRD's current housing-benefit guide before relying on it for a filing.

Illustration — Share option gain: OMV at exercise, less strike price and option cost Module 9, Ch.4 §4.3 — s.9(1)(d)/(4)

An employee is granted an option (by virtue of employment) to buy 5,000 shares at a strike price of $12/share, paying $6,000 for the option itself. Open market value (OMV) at grant was $24/share; two years later he exercises when OMV has risen to $30/share.

OMV at exercise (5,000 × $30)$150,000
Less: consideration paid on exercise (5,000 × $12)($60,000)
Less: cost of the option itself($6,000)
Chargeable gain, assessed in year of exercise$84,000

The gain is taxed at exercise, not at eventual sale — any share-price movement after exercise is a capital (non-taxable) matter. No allowance/rate figures involved, so no correction was needed.

Illustration — Termination gratuity "related back" over a 36-month window Module 9, Ch.4 §4.6 — s.11D(b)(i)

An employee made redundant after 7 years 11 months of service receives a $140,400 contract-end gratuity and elects to have it "related back" under s.11D(b)(i). Because total service exceeded 3 years, the law spreads the gratuity evenly over the 36 months ending on the earlier of the payment date or last day of employment — not over the full 7-year service period.

Year of assessmentMonths in the 36-month windowGratuity allocated
Year 1 (partial)8$31,200
Year 212$46,800
Year 312$46,800
Year 4 (partial)4$15,600
Total36$140,400

Contrast: for service of 3 years or less, the gratuity spreads only over the actual contract/service period, not artificially capped at 36 months. Pure time-apportionment mechanic — no correction needed.

Illustration — Child allowance depends on "full-time education," not just age Module 9, Ch.4 §4.9 — s.31

Twins both turn 19 partway through a year and finish secondary school that same year — the allowance still applies for that year since both were in full-time education for part of it (age >18 doesn't disqualify a student). The following year, one twin enrols in a full-time vocational diploma (still qualifies); the other instead starts a technician apprenticeship structured as an employment contract — drawing a wage as an employee rather than being a student — which fails the "full-time education" condition.

YearChildren qualifyingChild allowance claimable (YA 2026/27: $140,000/child; D26 exam basis YA 2025/26: $130,000)
Year twins turn 19Both twins2 × $140,000 = $280,000
Following yearDiploma student only1 × $140,000 = $140,000

Original book figure used $100,000/child (correct for YA 2018/19, now stale); updated above to the current YA 2026/27 rate of $140,000/child. Mechanic: no age cap while a child remains in full-time education; a paid apprenticeship/employment contract breaks eligibility even though the person is still "training." Watch: the 2026 Policy Address (16 Sep 2026) proposes HKD 160,000 for a second or subsequent child born on or after 16 September 2026 — twins born years earlier stay at HKD 140,000, so this illustration is unaffected even once the amendment ordinance passes.

Illustration — Full computation: salary, housing benefit, share option gain, deductions, allowances, tax payable Module 9, Ch.4 §4.11 — the "master" illustration

A bank compliance director receives salary $1,500,000, bonus $200,000, a rent-free company flat (taxed via the 10% rental-value method), and a gain on exercising vested overseas stock options. He deducts a professional subscription, self-education fees, a charitable donation, and mandatory MPF, and claims the basic and child allowances (married, assessed as an individual).

Salary + bonus$1,700,000
Add: rental value = 10% × (salary+bonus − professional subscription)$169,882
Add: share option exercise gain (FX-converted)$25,476
Assessable income$1,895,358
Less: professional subscription($1,179)
Less: self-education expenses($77,100)
Net assessable income$1,817,079
Less: approved charitable donation($50,000)
Less: mandatory MPF contribution (capped)($18,000)
Net income$1,749,079
Less: basic allowance (YA 2026/27; D26 exam: $132,000)($145,000)
Less: child allowance × 1 (YA 2026/27; D26 exam: $130,000)($140,000)
Net chargeable income$1,464,079
Tax at progressive rates vs. standard rate — pay the lower
Progressive rates on $1,464,079 net chargeable income (2%/6%/10%/14% on the first four $50,000 bands, 17% on the $1,264,079 remainder)$230,893
Standard rate: 15% × $1,749,079 net income (well under the $5,000,000 cap)$262,362
Tax payable = lower of the two$230,893

Original book figures used a basic allowance of $132,000 (YA 2019/20 rate) and child allowance of $120,000 — both stale; updated above to the current YA 2026/27 rates of $145,000 and $140,000, which cascades through to a different net chargeable income and tax payable than the book's original answer. Note: a one-off percentage tax reduction (capped at a fixed HKD amount) is announced in most Budgets and would further reduce this figure for the specific year being computed — check the current year's Budget measure before treating $230,893 as the final "net tax payable" (see the one-off relief callout on the main Salaries Tax page).

C. Personal Assessment — from Module 9 (Textbook)

Personal Assessment (§6 of the main page) aggregates salaries, property, and unincorporated-business income into one computation. These three illustrations, adapted from Module 9's running "Chan/Lip family" case study, are recomputed against current allowances/rate bands throughout.

Illustration — Should a sole proprietor with rental property elect Personal Assessment? Module 9, Ch.6 §6.3 — s.41

A taxpayer runs a sole-proprietorship business (profit $800,000, of which he donates $400,000 to charity) and separately owns a rental property (rental income $400,000), while paying $400,000 mortgage interest on his own home. Without election, profits tax and property tax are assessed separately with no relief for the home loan interest at all, and the charitable donation is capped at 35% of the business profit alone.

ItemWithout electionWith Personal Assessment
Business profit, after donation capped at 35% of $800,000 ($280,000 used, $120,000 of the $400,000 paid gets no relief)Profits tax @15% on $520,000 = $78,000Combined income $840,000, less a recomputed donation ceiling (35% of grossed-up income — $112,000 more becomes usable), less home loan interest (capped at $100,000/yr), less married allowance ($290,000) → net chargeable income $338,000 → tax at progressive rates = $39,460
Rental property, NAV after 20% allowanceProperty tax @15% on $320,000 = $48,000
Total$126,000
Tax saved by electing$86,540

Original book figures used the 2017/18 married allowance ($264,000) and old 4-band rates; updated above to current allowances/bands. Key trap: under Personal Assessment, the charitable donation ceiling is recomputed as 35% of the grossed-up combined income, not simply 35% of the post-donation business profit — this typically unlocks extra donation relief. Home loan interest also becomes claimable for the first time once there is a combined computation to set it against, even though the taxpayer has no salaries income. Figures exclude any one-off Budget tax reduction for the specific year being computed — check the current year's measure before treating either total as final.

Illustration — Married couple, joint election: salaries + property + business + partnership loss Module 9, Ch.6 §6.4 — s.41(1A)

Husband has salaries income $520,000 plus a $120,000 share of a partnership loss. Wife owns a rental property (NAV $192,000, mortgage interest ≥ $192,000) and runs a business (net profit $400,000 after an approved donation already used at business level). One 15-year-old child.

Husband's income − partnership loss share$520,000 − $120,000 = $400,000
Wife's income − mortgage interest (capped at NAV) − extra donation relief$692,000 − $192,000 − $160,000 = $340,000
Combined reduced total income$740,000
Less: married allowance (current rate)($290,000)
Less: child allowance × 1 (current rate)($140,000)
Net chargeable income$310,000
Tax at progressive rates$34,700

Tax is then apportioned back to each spouse in proportion to their own net contribution to the combined income: husband $400,000/$740,000 × $34,700 ≈ $18,757; wife $340,000/$740,000 × $34,700 ≈ $15,943.

Original book figures used the 2017/18 married allowance ($264,000) and child allowance ($100,000); updated above to current rates ($290,000 / $140,000). Mechanic: aggregating income across both spouses, capping loan interest at the property's own NAV (not the higher amount actually paid), and apportioning the joint tax bill back to each spouse by their share of net income — not a 50/50 split.

Illustration — Dependent parent allowance, elderly care deduction, and a business loss driving one spouse's share to zero Module 9, Ch.6 §6.5 — ss.26D, 31

Husband has employment income (incl. a share option gain), pays for his elderly mother's support (not living with him) and his elderly father's residential care home fees. Wife has no employment, runs a business at a loss for the year, and owns a rental property with mortgage interest exceeding its NAV.

Husband's net assessable income + Wife's NAV$1,368,000 + $105,600 = $1,473,600
Less: mortgage interest (capped at wife's NAV)($105,600)
Less: approved donation, MPF (capped)($10,000 + $18,000)
Less: elderly residential care expenses (current cap $120,000/parent)($120,000)
Less: wife's business loss for the year($450,000)
Reduced total income$770,000
Less: married allowance (current rate)($290,000)
Less: dependent parent allowance (60+, not co-residing — current rate)($55,000)
Net chargeable income$425,000
Tax at progressive rates$54,250

Original book figures used 2017/18 rates throughout (married allowance $264,000, dependent parent allowance $46,000, elderly care cap $92,000); all updated above to current rates. Because the wife's own income is more than wiped out by her mortgage interest, donation, and business loss, her apportioned share of the joint tax floors at nil — the husband bears the entire $54,250. Note the dependent parent allowance (mother, not co-residing) and the elderly care deduction (father, in a care home) apply to different dependants — you cannot double-claim both reliefs for the same parent, but can use different reliefs for different parents in the same year.

Figures to re-verify before publishing The elderly residential care expenses cap and any one-off percentage tax reduction (with its HKD cap) are announced fresh in most annual Budgets — confirm both against the current year's Budget measure before treating any "final tax payable" figure above as authoritative. The MPF mandatory-contribution cap ($18,000) and 35%-of-income donation ceiling are carried through from established practice; a quick check against current IRD guidance is still worthwhile before publishing.

← Back to Property Tax rules

Business — Property Tax

Property Tax — Worked Illustrations

Every worked example backing the Property Tax page — drawn from IRD's DIPNs and from Module 9: Principles of Taxation (4th ed.). The 15% standard rate and 20% statutory allowance are unchanged in current law, so these textbook figures needed no correction.

物業稅例題用租金、差餉、租客代付開支、不可收回租金及公司持有物業情境練習 NAV 計算。
Sources & attribution Two kinds of source, labelled inline on every illustration. DIPN/SOIPN examples are paraphrased from IRD's own published notes — never reproduced verbatim; each links to the DIPN Index, where the Official column points to IRD's authoritative PDF. Textbook examples are adapted from Module 9: Principles of Taxation (4th ed.), a professional qualification manual: the fact patterns are restated in our own words, the numbers are independently recomputed against current law, and where the book's figure is now stale it is shown alongside the corrected one. No textbook text is reproduced. These are study notes — see the licence: readable and linkable, not licensed for redistribution.

A. From IRD DIPNs

Illustration — Premium spread over the statutory 3-year cap DIPN 14

A $60,000 premium is paid for a 5-year lease running from 1 June 2006 to 31 May 2011 (60 months). Because s.5B(4) caps the spreading period at 3 years (36 months) even though the lease itself runs 5 years, the premium is spread over 36 months only:

Year of assessmentMonths falling in yearAssessable value included
2006/0710 of 36$16,667
2007/0812 of 36$20,000
2008/0912 of 36$20,000
2009/102 of 36$3,333

Nothing is assessed for 2010/11 or 2011/12 even though the lease itself continues — the 3-year statutory cap has already fully absorbed the premium.

Illustration — Net assessable value computation chain DIPN 14

The DIPN sets out the standard computation chain: Consideration receivable, plus rent recovered previously written off, less irrecoverable rent, gives Assessable Value; deduct rates paid by the owner (if any); deduct the flat 20% statutory allowance on the balance, to arrive at Net Assessable Value — the figure to which the 15% standard rate is applied.

Illustration — Premium taxed twice under two different spreading rules DIPN 4 (see also Profits Tax page)

Where the property owner is also carrying on a property-dealing/letting trade, the same premium is spread differently for the two taxes: over the full lease term (no cap) for Profits Tax purposes as a trading receipt, but capped at 3 years for Property Tax purposes under s.5B(4). The s.25 set-off then reconciles the two — see the full worked example on the Profits Tax illustrations page.

B. From Module 9: Principles of Taxation (4th ed.)

Adapted from a professional taxation qualification manual, following its running "Tong family" case study. Facts are paraphrased, not reproduced verbatim. The 15% standard rate and 20% statutory allowance used throughout already match current law — no correction was needed for this topic.

Illustration — Premium spreading: lease term shorter than, equal to, and longer than the 3-year cap Module 9, Ch.5 §5.2 — s.5B(3)/(4)

Three properties are let on different lease terms, each with a lump-sum premium spread evenly over the lease period or 3 years, whichever is shorter:

PropertyLease termPremiumSpreading
A5 years (60 months)$360,000Capped at 36 months → $10,000/month for 3 years, then nil for the remaining 2 years
B3 years (36 months, exactly)$240,000Full term used (36 = cap) → $6,667/month throughout
C2 years (24 months)$144,000No cap needed → $6,000/month throughout

Property A shows the cap actually biting: the $360,000 premium is fully exhausted at month 36, and nothing further is assessed for the lease's remaining 24 months even though the tenancy continues.

Illustration — Full net assessable value computation, three properties Module 9, Ch.5 §5.3 — DIPN 14 template

Three commonly-tested variations on the NAV computation chain (all at the current 15%/20% rates):

Property A (jointly owned)Property BProperty C
Rent for the year$600,000$240,000$120,000
Add: premium instalment$80,000$80,000$60,000
Add: other consideration (furniture/repairs borne by tenant/rent recovered/management fee, as applicable)—$37,000$14,000
Assessable value$680,000$357,000$194,000
Less: rates paid by owner($16,000)— (tenant pays rates)—
Less: 20% statutory allowance($132,800)($71,400)($38,800)
Net assessable value$531,200$285,600$155,200
Tax @ 15%$79,680 (split 50/50: $39,840 each)$42,840$23,280

Key traps illustrated: (1) rates are only deductible if the owner agreed to bear them — Property B's tenant pays rates, so no deduction; (2) government rent, management fees, mortgage interest, and repair costs actually paid by the owner are never separately deductible — the flat 20% allowance is deemed to cover all of them regardless of actual spend.

Illustration — Irrecoverable rent exceeding the year's own rent, carried back Module 9, Ch.5 §5.4 — s.7C

A 2-year tenancy at $10,000/month runs from 1 July 2016; the tenant stops paying from 1 January 2017 and disappears on 1 May 2017, with the assessor accepting the outstanding rent as bad.

Original YA1 (filed before default known, 9 months' rent)YA2 (year debt confirmed bad)
Rent / assessable value$90,000$10,000
Less: bad debt confirmed irrecoverable (4 months, Jan–Apr)—($40,000)
Result for YA2—($30,000) — a loss

Since the $40,000 bad debt exceeds YA2's own $10,000 rent, the $30,000 excess is carried back under s.7C(3) to amend YA1:

YA1 revised: $90,000 rent − $30,000 carried-back loss$60,000
Less: 20% statutory allowance($12,000)
Revised NAV$48,000
Revised tax @15% ($7,200) vs. originally paid ($10,800)Refund of $3,600

Mere non-payment (without the debt being proved bad) gives no deduction at all — this only applies once the assessor accepts the rent as genuinely irrecoverable.

Illustration — Property tax set off against profits tax for a corporation Module 9, Ch.5 §5.6 — s.25

A company's rental income is already included in its accounts and taxed under profits tax. It did not apply for the s.5(2)(a) upfront exemption, and separately paid $3,000 property tax on the same property.

Profits tax payable for the year$10,000
Less: property tax already paid on the same property($3,000)
Net profits tax payable$7,000

A straight set-off, unaffected by rate levels — if property tax paid had exceeded the profits tax bill, the excess would be refundable instead.

← Back to Stamp Duty rules

Business — Stamp Duty

Stamp Duty — Worked Illustrations

Every worked example backing the Stamp Duty page — drawn from IRD's SOIPNs and from Module 9: Principles of Taxation (4th ed.). This is the chapter needing the most correction of any topic: both source books were written before the 2023 AVD Scale 1 reform and/or the 2024 BSD/SSD rate cut, so most of their headline rates are now wrong — corrected figures are shown alongside the originals throughout.

印花稅例題以物業買賣、公司買樓、香港股票轉讓及關聯公司重組練習印花稅分析。
Sources & attribution Two kinds of source, labelled inline on every illustration. DIPN/SOIPN examples are paraphrased from IRD's own published notes — never reproduced verbatim; each links to the DIPN Index, where the Official column points to IRD's authoritative PDF. Textbook examples are adapted from Module 9: Principles of Taxation (4th ed.), a professional qualification manual: the fact patterns are restated in our own words, the numbers are independently recomputed against current law, and where the book's figure is now stale it is shown alongside the corrected one. No textbook text is reproduced. These are study notes — see the licence: readable and linkable, not licensed for redistribution.

A. From SOIPNs

Illustration — Provisional vs formal agreement timing SOIPN 1

Provisional agreement signed 1 March 2014, formal agreement signed 8 March 2014 (within 14 days) → only the formal agreement needs stamping, by 7 April 2014; the provisional agreement is duty-free. If the formal agreement instead follows more than 14 days later (e.g. 17 March), the provisional agreement itself becomes chargeable at full AVD by 31 March 2014, and the formal agreement is separately chargeable at a fixed $100 by 16 April 2014.

Illustration — AVD on a multi-asset instrument (residential + car parks) SOIPN 8, historical figures — pre-2023 flat-15% Scale 1

An HKPR buyer purchases a $13,000,000 residential property plus two car parking spaces worth $2,000,000 in one instrument. Scale 2 (3.75% at that value band) applies to the residential portion: $487,500. The car parks (non-residential, Scale 3) at the equivalent band: $150,000. Total AVD = $637,500. Historically (SOIPN 8, Nov 2018), a non-HKPR buyer paid a flat 15% Scale 1 on the residential portion instead: $1,950,000 + $150,000 = $2,100,000 — but Scale 1 is no longer flat; see illustration B1 below for how the same fact pattern is taxed today.

Illustration — Current graduated Scale 1 vs. Scale 2 Corrected from Cap. 117 First Schedule, post-2026 amendment

Same $13,000,000 residential property, non-HKPR (or corporate) buyer, no Scale 2 concession available: Scale 1 is graduated exactly like Scale 2 at this value band (3.75%), giving the same $487,500 — not a flat-15% $1,950,000. The two scales only diverge for a single residential property with consideration above $100,000,000: at $150,000,000, Scale 2 (HKPR sole property) still applies its 4.25% top rate = $6,375,000, while Scale 1 hits the new 6.5% flat band = $9,750,000 — a HKD 3.375 million difference driven entirely by the 2026 amendment's new top bands.

Illustration — SSD tiered by holding period SOIPN 5

Under the (now 0%-rated but still operative) post-27-Oct-2012 regime: a $3,000,000 residential property resold within 6 months would attract SSD at 20% ($600,000); resold within 6–12 months, 15% ($450,000); a $4,000,000 property resold within 12–36 months, 10% ($400,000). At the current 0% rate none of this is actually payable, but the tiering logic remains the statutory mechanism.

Illustration — BSD ignores which joint owner actually paid SOIPN 7

A Hong Kong permanent resident buys a $4,000,000 residential property jointly with an unrelated non-HKPR co-buyer. Because one joint owner is a non-HKPR and the two are not close relatives, BSD (at the applicable rate) applies to the full $4,000,000 value — it is not pro-rated to only the non-HKPR's share.

B. From Module 9: Principles of Taxation (4th ed.)

Adapted from a professional taxation qualification manual. Facts are paraphrased, not reproduced verbatim. This textbook predates the 2023 Scale 1 reform and the Feb 2024 BSD/SSD rate cut — every AVD/BSD/SSD figure below has been recomputed against current (2026) law, with the book's original figure shown for contrast.

Illustration B1 — AVD on residential + non-residential property in one purchase Module 9, Ch.7 §7.4

A Hong Kong company (never a HKPR) buys two properties on the same day: a commercial warehouse for $25,000,000, and a residential flat for $20,000,000 (consideration assumed to equal market value in both cases).

PropertyScaleBook figure (flat 15% on residential)Current law (graduated)
Warehouse (non-residential)Scale 3, 4.25% band$1,062,500$1,062,500 (unchanged)
Residential flatScale 1, "$6.72M–$20M" band, 3.75%$3,000,000 (flat 15%)$750,000

Original book figure used $3,000,000 (flat 15% Scale 1, the 2016–2023 rule); current law figure is $750,000 — a 75% reduction. The flat-15% Scale 1 was replaced by the same graduated table Scale 2 uses back in 2023; the 2026 amendment only adds new top bands above $100,000,000, irrelevant to a $20M deal.

Illustration B2 — Full AVD + SSD + BSD stack on a quick resale to a non-HKPR buyer Module 9, Ch.7 §7.6 — ss.24, 27

A residential flat is bought on 1 March 2018 and sold on 1 March 2019 (12 months + 1 day later) to a Mainland Chinese buyer who resides in HK ~183 days/year but holds no HK permanent ID — so he is not a HKPR for stamp duty purposes despite the residence. The stated price is $2,000,000 "subject to" an existing $5,000,000 mortgage, but market value at the (earlier, binding) contract date was $8,000,000. Because the transfer is at an undervalue and the debt is assumed, s.24 and s.27 deem the full $8,000,000 market value as the stampable amount for all three duties — that valuation mechanic is unaffected by any rate change.

DutyBook figureCurrent law (2026)Why
AVD$1,200,000 (flat 15%)$300,000 (3.75% graduated)Flat-15% Scale 1 superseded 2023
SSD (holding >12mo, ≤36mo tier)$800,000 (10% tier)$0SSD rate cut to 0% from 28 Feb 2024 (tier logic itself unchanged)
BSD$1,200,000 (flat 15%)$0BSD rate cut to 0% from 28 Feb 2024
Fixed duty on assignment$100$100 (unchanged)—
Total$3,200,100$300,100Over 90% lower today

Residence alone (183 days/year) does not confer HKPR status — the buyer here is a non-HKPR by ID/citizenship regardless of how much time he spends in Hong Kong.

Illustration B3 — Gift between close relatives: Scale 2 applies regardless of the recipient's residency Module 9, Ch.7 §7.6 — s.27, s.29AJ

A father gifts a residential flat (market value $10,000,000) to his son, a Canadian citizen with no HK permanent ID. Nil consideration is disregarded as a voluntary disposition — full market value is used. Because the transfer is between close relatives (parent–child), Scale 2 applies regardless of the son's residency status, and both BSD and SSD are exempt on the same close-relative basis.

AVD, Scale 2, "$6.72M–$20M" band, 3.75%$375,000
SSDExempt (close relative)
BSDExempt (close relative)

No correction needed — Scale 2 rates were not touched by the 2026 amendment, so the book's $375,000 figure is still correct today. Included deliberately as a contrast case: not every textbook figure in this chapter is wrong.

Illustration B4 — Hong Kong share transfer with failed group relief Module 9, Ch.7 §7.2 — s.45

A Hong Kong holding company transfers a 10% stake in an HKSE-listed (but overseas-incorporated) company to its 80%-owned subsidiary for $400,000, though market value is $500,000. Because the shares are HKSE-listed, they are Hong Kong stock for stamp duty purposes regardless of the issuer's place of incorporation. Group relief under s.45 fails — the parent only owns 80% of the subsidiary (below the 90% threshold), and an individual co-owner's personal stake cannot count toward that 90% test. The transfer at an undervalue is a voluntary disposition, so duty is charged on the higher $500,000 market value.

Stamp duty: $500,000 × 0.2%$1,000
Plus: fixed duty on the instrument of transfer$5

No correction needed — the 0.2% rate (0.1% buyer / 0.1% seller) matches current law exactly. Flag: elsewhere in the same textbook chapter, a rate of 0.26% is quoted — that was only correct for the temporary uplift period 1 Aug 2021–16 Nov 2023 and is now obsolete; 0.2% (as used in this illustration) is the figure to rely on.

Illustration B5 — Lease duty by term band (constructed — the textbook gives only the rate table, no worked figures) Module 9, Ch.7 §7.5, rate table only

A 5-year shop lease at $50,000/month rent, no premium. Term exceeds 3 years, so the 1% rate applies to average yearly rent.

Average yearly rent ($50,000 × 12)$600,000
Lease duty (1% of average yearly rent)$6,000

Rate bands (unchanged, current): 0.25% (≤1yr/undefined), 0.5% (1–3yr), 1% (>3yr) of average annual rent. If the lease is first executed as an "agreement for lease," that instrument bears this duty; a later formal lease on the same terms bears only a nominal $3 fixed duty.

Bottom line for this chapter Every AVD/BSD/SSD figure quoted in older study material — this textbook included — should be treated as showing the mechanic (which band, which test, which exemption) correctly, but the rate itself needs a fresh check against the Stamp Duty page's corrected tables before use in any real computation.

← Back to Depreciation & Allowances rules

Common — Depreciation & Allowances

Depreciation & Allowances — Worked Illustrations

Every worked example backing the Depreciation & Allowances page — drawn from IRD's DIPNs and from Module 9: Principles of Taxation (4th ed.). The 60% initial / 10%-20%-30% annual plant & machinery rates are unchanged in current law, so this topic needed no rate corrections.

折舊及免稅額例題透過池制、出售資產、商業建築物、翻新及指定固定資產練習折舊免稅額。
Sources & attribution Two kinds of source, labelled inline on every illustration. DIPN/SOIPN examples are paraphrased from IRD's own published notes — never reproduced verbatim; each links to the DIPN Index, where the Official column points to IRD's authoritative PDF. Textbook examples are adapted from Module 9: Principles of Taxation (4th ed.), a professional qualification manual: the fact patterns are restated in our own words, the numbers are independently recomputed against current law, and where the book's figure is now stale it is shown alongside the corrected one. No textbook text is reproduced. These are study notes — see the licence: readable and linkable, not licensed for redistribution.

A. From IRD DIPNs

Illustration — Industrial building sale: buyer/seller allowance split DIPN 2

A factory is built for $500,000 in February 1992. Initial allowance 20% = $100,000; annual allowance 4% = $20,000 in the first year, continuing for 3 more years, leaving a residue of expenditure of $320,000. The building is then sold for $420,000. The seller faces a balancing charge of $100,000 (sale price exceeds residue by $100,000, capped at allowances previously granted). The buyer's future annual allowance is recalculated as 1/21 (years remaining to the 25th year) × $420,000 = $20,000/year.

Illustration — Plant & machinery pooling across two rate classes DIPN 7

A taxpayer buys a motor car for $150,000 and 3 cookers for $50,000 (both 30% pool), plus office furniture for $20,000 and air-conditioning for $28,000 (both 20% pool). Year 1: 30% pool — cost $200,000, initial allowance 60% = $120,000, annual allowance on the remaining $80,000 at 30% = $24,000. 20% pool — similar mechanics give a smaller annual allowance. Total first-year depreciation allowance across both pools: $176,640.

Illustration — Balancing charge capped at allowances previously granted DIPN 7

On cessation of a business, a 30% pool with a reducing value brought forward of $21,000 (original cost $75,000) is sold for $80,000. Although sale proceeds ($80,000) exceed the reducing value ($21,000) by $59,000, the balancing charge is capped at $54,000 — the total allowances previously granted ($75,000 cost − $21,000 residue) — never more than was originally allowed.

Illustration — Accelerating pre-2018/19 environmental instalments to 100% DIPN 5

Company-HK pays $15M, $20M and $30M in May 2016/2017/2018 respectively for environmental protection installations, under the pre-2018/19 5-instalment (20%/year) regime. Electing under s.16I(3A) to accelerate all remaining instalments to 100% in 2018/19 gives total cumulative deductions of $3,000,000 (2016/17) + $7,000,000 (2017/18) + $55,000,000 combined by 2018/19 (remaining instalments on the first two payments, plus 100% of the third).

Illustration — Specified IP Right deduction spread to match remaining protection DIPN 49

A copyright costing $400,000 has protection expiring in YA2022/23. Rather than the standard 5 equal instalments, the deduction is compressed into the 4 years actually remaining: $100,000/year for YA2019/20–2022/23.

B. From Module 9: Principles of Taxation (4th ed.)

Adapted from a professional taxation qualification manual. Facts are paraphrased, not reproduced verbatim. The plant & machinery pooling rates (60% initial; 10%/20%/30% annual) are unchanged in current law — no correction was needed.

Illustration — Plant & machinery pooling across two years, with disposals and additions Module 9, Ch.3 §3.7.1 — adapted from DIPN 7

A business starts trading on 2 February 2018. In its first year it buys a car ($150,000) and 3 electric cookers ($50,000) — both 30% pool — plus office furniture ($20,000) and 2 air-conditioning units ($28,000) — both 20% pool.

Year 1 (YA 2018/19)
30% pool20% pool
Cost$200,000$48,000
Less: initial allowance (60%)($120,000)($28,800)
Less: annual allowance (30% / 20% of remainder)($24,000)($3,840)
Reducing value carried forward$56,000$15,360

Total Year 1 depreciation allowance across both pools: $120,000 + $28,800 + $24,000 + $3,840 = $176,640.

In Year 2: the car is written off in an accident (insurance + scrap recovery $31,000); a new van is bought for $180,000; a cooker is sold for $3,000 (total 30%-pool disposal proceeds $34,000); an air-conditioning unit is sold for $2,000 and replaced with a new one for $8,000.

Year 2 (YA 2019/20)
30% pool20% pool
Reducing value brought forward$56,000$15,360
Add: new assets$180,000$8,000
Less: initial allowance (60% of new assets)($108,000)($4,800)
Less: disposal proceeds($34,000)($2,000)
Less: annual allowance($28,200)($3,312)
Reducing value carried forward$65,800$13,248

Total Year 2 depreciation allowance: $108,000 + $4,800 + $28,200 + $3,312 = $144,312. Disposal proceeds simply reduce the pool's reducing value — they don't trigger a balancing charge unless they exceed it (see the DIPN 7 illustration above for that scenario). Rates used (60% initial, 30%/20% annual) match current law exactly — no correction needed.

Extra practice

Module 9 Extra Practice Q&A

Additional paraphrased illustrations and exam-style questions based on the HKICPA Module 9 Principles of Taxation textbook, 4th edition. These are study notes, not copied textbook answers. Check the current IRO, SDO, Budget measures, and IRD guidance before using any figure in a filing position.

Module 9 額外練習問答改寫練習庫,按利得稅、薪俸稅、物業稅、個人入息課稅、印花稅及跨境預扣稅分類。
Sources & attribution Two kinds of source, labelled inline on every illustration. DIPN/SOIPN examples are paraphrased from IRD's own published notes — never reproduced verbatim; each links to the DIPN Index, where the Official column points to IRD's authoritative PDF. Textbook examples are adapted from Module 9: Principles of Taxation (4th ed.), a professional qualification manual: the fact patterns are restated in our own words, the numbers are independently recomputed against current law, and where the book's figure is now stale it is shown alongside the corrected one. No textbook text is reproduced. These are study notes — see the licence: readable and linkable, not licensed for redistribution.
Source and copyright note This section uses the Module 9 textbook as a learning source and rewrites the material into new practice prompts, short answers, and compact computations. It does not reproduce full textbook questions or worked examples.

1. Profits Tax - Trading, Source, Deductions

Illustration PT-1 Badges of trade

Question. A company buys a shop unit with short-term bank finance, renovates it lightly, advertises it for resale within three months, and sells at a gain. Is the gain likely capital or trading?

中文題目:一間公司以短期銀行貸款購入商舖,簡單裝修後三個月內放售並賺取收益。該收益較可能屬資本性質,還是營業買賣收益?

Answer. It is likely trading. Short holding period, financing arranged for quick turnover, resale activity, and commercial organization all point toward an adventure in the nature of trade. The label in board minutes is useful evidence, but the whole fact pattern matters more.

中文答案:較可能屬營業買賣收益。持有期短、以短期融資支持快速轉售、有主動放售行為及商業組織安排,都指向「屬貿易性質的一次性交易」。董事會紀錄的說法有參考價值,但最終仍要整體看事實。

Illustration PT-2 Capital asset disposal

Question. A retailer buys a warehouse for storage, uses it for several years, then sells it after receiving an unsolicited offer. Is the gain automatically taxable because the seller is a business?

中文題目:零售商購入倉庫作儲貨用途,使用數年後因收到買家主動出價而出售。是否因賣方是商業機構,收益便自動須課利得稅?

Answer. No. A business can hold capital assets. If the warehouse was acquired and used as a fixed capital facility rather than trading stock, the gain is more likely capital and outside profits tax, subject to the facts.

中文答案:不是。商業機構也可以持有資本資產。如果倉庫購入及使用目的均屬固定資本設施,而非買賣存貨,出售收益較可能屬資本性質,不屬利得稅課稅範圍;但仍須視乎全部事實。

Illustration PT-3 Source of service income

Question. A Hong Kong company signs contracts in Hong Kong but its staff perform all consultancy fieldwork in Japan. Where should the source analysis focus?

中文題目:香港公司在香港簽約,但員工全部顧問實地工作均在日本進行。判斷利潤來源地時應集中看甚麼?

Answer. Focus on what the taxpayer did to earn the fee and where those profit-producing operations took place. For service income, performance of the services usually carries strong weight; contract signing alone is not always decisive.

中文答案:重點是納稅人做了甚麼來賺取該收入,以及產生利潤的實際操作在何處進行。服務收入通常很重視服務履行地;單靠簽約地點未必具決定性。

Illustration PT-4 Bad debt deduction

Question. A trading debt of HK$90,000 was previously booked as taxable sales income and is later written off as irrecoverable. A separate staff loan of HK$40,000 is also written off. Which write-off is deductible?

中文題目:一筆 HK$90,000 貿易應收款曾計入應課稅銷售收入,後來證實不能收回並撇銷;另有 HK$40,000 員工貸款亦撇銷。哪一項可扣稅?

Answer. The trading debt is deductible because it arose from taxable trading receipts already brought into account. The staff loan is normally not deductible for an ordinary trader because making staff loans is not its money-lending business and the loan principal was not taxable income.

中文答案:貿易壞帳可扣稅,因為它源自已入帳的應課稅營業收入。員工貸款一般不可扣稅,因普通貿易公司並非經營放債業務,而貸款本金亦從未作為應課稅收入入帳。

Question PT-5 Quick MCQ

Question. Which expense is most clearly deductible for profits tax?

中文題目:以下哪項開支最明顯可作利得稅扣除?

A. Private rent of the managing director. B. Capital cost of acquiring a liquor licence. C. Interest on a commercial loan used to buy trading stock, assuming the interest rules are met. D. Cost recovered from an insurer.

Answer. C. The borrowing is for trading stock and can satisfy the production-of-profits test, but interest must still pass the specific interest deduction conditions.

中文答案:C。借款用於購買營業存貨,較能符合「產生應課稅利潤」的要求;但利息仍須通過利息扣除的特定條件。

2. Salaries Tax - Employment Income and Benefits

Question ST-1 Employment vs self-employment

Question. A marketing worker has fixed office hours, uses the company's equipment, reports to a director, and receives a monthly salary plus commission. Salaries tax or profits tax?

中文題目:市場推廣人員有固定辦公時間,使用公司設備,向董事匯報,並收取月薪加佣金。應較可能屬薪俸稅還是利得稅?

Answer. Salaries tax is more likely. Control, integration into the employer's organization, and lack of entrepreneurial risk point to employment rather than an independent profession or business.

中文答案:較可能屬薪俸稅。受僱主控制、融入僱主組織、缺乏自行承擔營商風險,均指向僱傭關係而非獨立專業或業務。

Question ST-2 Contract for services

Question. A consultant serves several clients, rents her own office, hires assistants, bears overheads, and invoices fixed project fees. What tax head is more likely?

中文題目:一名顧問服務多名客戶,自租辦公室、聘請助理、自行承擔營運開支,並按項目收費。較可能屬哪一稅種?

Answer. Profits tax is more likely. She appears to be carrying on a profession or business on her own account rather than holding an employment.

中文答案:較可能屬利得稅。她看似以自己名義經營專業或業務,而非受僱於單一僱主。

Question ST-3 Share option timing

Question. An employee receives an employment-related share option and later exercises it at a discount. When is the benefit normally measured?

中文題目:僱員因受僱關係取得股份期權,其後以折讓價行使。通常何時計算應課稅利益?

Answer. The taxable benefit is generally measured when the option is exercised, released, or assigned, depending on the event, with the gain computed by reference to the relevant market value and exercise price rules.

中文答案:一般在期權被行使、放棄或轉讓時,按相關事件計算應課稅利益,通常會參考市值與行使價等規則計算收益。

3. Property Tax - Rental Income and Corporate Owners

Illustration PrT-1 Tenant-paid expenses

Question. A tenant pays HK$20,000 repair costs that the landlord was obliged to bear under the lease. Is the payment ignored for property tax?

中文題目:租客支付 HK$20,000 修葺費,而根據租約該費用本應由業主承擔。物業稅是否可忽略該款項?

Answer. No. Where the tenant discharges an obligation of the owner, the amount can be treated as consideration for use of the property. The statutory 20% allowance then applies in computing net assessable value.

中文答案:不可忽略。若租客代業主履行責任,該款項可被視為使用物業的代價,然後在計算應評稅淨值時扣除 20% 法定修葺免稅額。

Illustration PrT-2 Simple NAV computation

Question. Annual rent is HK$360,000. Rates of HK$12,000 are paid by the owner. No irrecoverable rent. Compute net assessable value.

中文題目:全年租金 HK$360,000,差餉 HK$12,000 由業主支付,沒有不能追回租金。計算應評稅淨值。

Assessable value before allowance: 360,000 - 12,000 = 348,000
Less statutory repairs allowance: 348,000 x 20% = 69,600
Net assessable value: 278,400

Answer. NAV is HK$278,400.

中文答案:應評稅淨值為 HK$278,400。

Question PrT-3 Corporate property owner

Question. A Hong Kong company lets out an office and the rental income is already included in profits tax. Can it avoid double tax under property tax?

中文題目:香港公司出租辦公室,租金收入已納入利得稅課稅。可否避免再繳物業稅?

Answer. A corporation can usually seek exemption from property tax where the property income is chargeable to profits tax. The rental stream is then dealt with under profits tax rather than being taxed twice.

中文答案:公司如相關物業收入已須繳利得稅,通常可申請豁免物業稅,避免同一租金收入被重複課稅。

4. Personal Assessment - Election and Loss Set-off

Illustration PA-1 Mortgage interest limit

Question. Under personal assessment, an individual has property NAV of HK$60,000 and interest of HK$75,000 on the loan used to buy that income-producing property. How much interest can be deducted against that property income?

中文題目:在個人入息課稅下,某人有物業應評稅淨值 HK$60,000,購買該收租物業的貸款利息為 HK$75,000。可扣除多少利息?

Answer. HK$60,000. The property-loan interest deduction is limited by the net assessable value of the relevant property included in personal assessment.

中文答案:HK$60,000。可扣除的物業貸款利息以納入個人入息課稅的相關物業應評稅淨值為上限。

Illustration PA-2 Business loss limit

Question. Total income after allowable deductions becomes negative because of concessionary deductions and a business loss. How much personal assessment loss can be carried forward?

中文題目:扣除特惠扣除及業務虧損後,總入息變成負數。可結轉的個人入息課稅虧損是多少?

Answer. The carry-forward personal assessment loss is limited to the business loss element. A deficit caused by personal allowances or non-business concessionary deductions is not carried forward as a business loss.

中文答案:可結轉的個人入息課稅虧損以業務虧損部分為限。由個人免稅額或非業務性特惠扣除造成的不足額,不會作為業務虧損結轉。

Question PA-3 Married couple election

Question. A married person wants personal assessment, but the spouse also has income chargeable to tax. Can one spouse elect alone?

中文題目:已婚人士想選擇個人入息課稅,但配偶亦有應課稅收入。一方可否單獨選擇?

Answer. Generally no. Where both spouses have income within the personal assessment framework, joint election is required. This is important when modelling whether personal assessment is beneficial.

中文答案:一般不可以。若夫婦雙方均有屬個人入息課稅框架內的收入,通常需要共同選擇。判斷個人入息課稅是否有利時必須留意這點。

5. Stamp Duty - Instruments, Property, Shares, Relief

Question SD-1 Instrument-based tax

Question. Why is it imprecise to say that stamp duty taxes "transactions"?

中文題目:為何說印花稅是對「交易」課稅並不精確?

Answer. Stamp duty is charged on instruments. A transaction matters because it produces or explains the instrument, but the charge is imposed by reference to the stampable document and the relevant charging head.

中文答案:印花稅是對文書課稅。交易本身重要,是因為它產生或解釋該文書;但真正課稅基礎是可予徵收印花稅的文件及相關課稅項目。

Illustration SD-2 Hong Kong stock transfer

Question. Hong Kong shares are sold for HK$100,000 but market value is HK$120,000. Which amount is used for ad valorem stamp duty?

中文題目:香港股票以 HK$100,000 出售,但市值為 HK$120,000。從價印花稅應以哪個金額計算?

Answer. HK$120,000. For Hong Kong stock transfers, duty is generally computed on the higher of consideration and value. Check the current stock duty rate before filing, as rates have changed over time.

中文答案:HK$120,000。香港股票轉讓一般按代價及價值兩者中較高者計算印花稅。由於股票印花稅率曾有變動,實際申報前應查核現行稅率。

Question SD-3 Associated company relief

Question. ParentCo transfers Hong Kong immovable property to a 100%-owned subsidiary. What relief may be relevant?

中文題目:母公司把香港不動產轉讓予其 100% 擁有的附屬公司。可能涉及哪項印花稅寬免?

Answer. Associated-company relief under SDO s.45 may be relevant if the ownership threshold and continuity conditions are satisfied. The parties must monitor the post-transfer association period because relief can be clawed back if the conditions break.

中文答案:如符合持股比例及持續關聯條件,可能適用《印花稅條例》第 45 條關聯公司寬免。轉讓後仍須監察關聯關係維持期,否則寬免可能被撤回。

6. Cross-border Profits Tax - Withholding and Non-residents

Question CB-1 Non-resident entertainer

Question. A Hong Kong event organizer pays a non-resident performer's company for a Hong Kong performance. Why might Hong Kong tax be withheld even if the performer is paid through a company?

中文題目:香港活動主辦方向非居民表演者的公司支付香港演出費。即使款項經公司支付,為何仍可能需要在香港預扣稅?

Answer. The IRO contains deeming and collection rules for non-resident entertainers and sportspeople. Interposing a company does not necessarily remove the Hong Kong charge where the performance activity is in Hong Kong.

中文答案:《稅務條例》對非居民演藝人員及運動員有視作收入及徵收規則。即使中間有公司收款,只要演出活動在香港進行,未必能避免香港稅務責任。

Illustration CB-2 Deemed profit method

Question. If the law taxes a non-resident entertainer on a deemed profit basis, what are the two moving parts in the computation?

中文題目:若法例以視作利潤方法向非居民表演者課稅,計算時主要有哪兩個變動部分?

Answer. First identify the gross payment that falls within the deeming rule. Then apply the statutory deemed-profit fraction and the applicable tax rate. If the actual-profit method is claimed, only properly connected deductible expenses should be used.

中文答案:第一,確定受視作規則涵蓋的總付款;第二,套用法定視作利潤比例及適用稅率。如改用實際利潤方法,只應扣除與香港演出適當相關的可扣稅開支。