Tax-5Adv

Hong Kong Departmental Inpterpretation and Practice Notes
	DIPN 01	Profits Tax Part A: Computing Assessable Profits Part B: Revenue Recognition Part C: Measurment of Inventories or Stock	Sep 2020	Ref Only
	DIPN 05	Profits tax deductions for expenditure on - Technical education Building refurbishment Prescribed fixed assets Environmental protection facilities	Apr 2019	Ref Only
	DIPN 10	The charge to salaries tax	Jun 2007
	DIPN 11	Field audit and investigation	Oct 2007
	DIPN 12	Commission, rebates and discounts	Sep 2001
	DIPN 13A	Deductibility of Interest Expenses	Dec 2004
	DIPN 15	(A) Limitation of loss relief (Section 22B) (B) Leasing arrangements (Section 39E) (C) General anti-avoidance provision (Section 61) (D) General anti-avoidance provision (Section 61A) (E) Loss companies (Section 61B) (F) Ramsay principle (G) Penalty on tax avoidance cases (H) Guidelines on lease financing (I) Advance rulings	Jan 2006
	DIPN 16	Salaries tax - Taxation of Fringe Benefits	Oct 2003	Ref Only
	DIPN 21	Locality of profits	Jul 2012
	DIPN 23	Recognized Retirement Schemes	May 2019	Ref Only
	DIPN 28	Profits Tax Deduction of Foreign Taxes	July 2019
	DIPN 31	Advance Rulings	Apr 2020
	DIPN 35	Concessionary deductions : Sections 26E and 26F Home loan interest	Feb 2020	Ref Only
	DIPN 36	Concessionary deductions : Section 26D Elderly residential care expenses	Feb 2020	Ref Only
	DIPN 37	Concessionary deductions : Section 26C Approved charitable donations	Feb 2020	Ref Only
	DIPN 39	Digital Economy Electronic Commerce and Digital Assets	Mar 2020
	DIPN 42	Profits tax - Part A : Taxation on financial instruments Part B : Taxation of foreign exchange differences	Jun 2020	Ref Only
	DIPN 44	Arrangement between the Mainland of China and the Hong Kong Special Administrative Region for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income	Aug 2008	Ref Only
	DIPN 45	Relief from double taxation due to transfer pricing or profit reallocation adjustments	Apr 2009	Ref Only
	DIPN 46	Transfer pricing guidelines - Methodologies and related issues	Dec 2009
	DIPN 47	Exchange of information	Jul 2020
	DIPN 48	Advance Pricing Arrangement	Jul 2020
	DIPN 49	Part A : Profits tax deduction of capital expenditure on relevant intellectual property rights Part B : Taxation of royalties derived from licensing of intellectual property right	Aug 2020
	DIPN 51	Profits Tax Exemption for Offshore Private Equity Fund	May 2016	Ref Only
	DIPN 52	Taxation of Corporate Treasury Activity	Sep 2016	Ref Only
	DIPN 55	Deduction for Research and Development Expenditure	Apr 2019
	DIPN 56	Concessionary Deductions: Sections 26H to 26M Health Insurance Premiums	Feb 2020	Ref Only
	DIPN 57	Concessionary Deductions: Sections 26N to 26U Annuity Premiums and MPF Voluntary Contributions	Feb 2020	Ref Only
	DIPN 58	Transfer Pricing Documentation and Country-by-Country Reports	Jul 2019
	DIPN 59	Transfer Pricing between Associated Persons	Jul 2019
	DIPN 60	Attribution of Profits to PE in Hong Kong	Jul 2019
	DIPN 61	Profits Tax Exemption for Funds	Jun 2020	Ref Only
	DIPN 63	Part A: Qualifying Amalgamation of Companies Part B: Transfer or Succession of Specified Assets without Sales	Nov 2023

CTA P5 Syllabus
P5 Hong Kong Tax Supplementary Notes
Hong Kong Tax Residency
P5 Wording
TP Threshold

Hong Kong Double Taxation Treaty Documents
		Comprehensive Double Taxation Agreements concluded	As at 24/08/2025
		Tax Information Exchange Agreements concluded	As at 24/08/2025
		The following table shows the maximum rates of tax those countries	As at 24/08/2025

Double Tax Treaty Convention
		BEPS Actions		Ref Only
		BEPS Members		Ref Only
		2017 Articles of the Model Tax Convention on Income and on Capital
		2014 Articles of the Model Tax Convention on Income and on Capital		Ref Only
		2008 Articles of the Model Tax Convention on Income and on Capital		Ref Only
		The Five Transfer Pricing Methods Explained _ With Examples

Others
		Chartered Tax Adviser – Code of Professional Conduct	Nov 2021
		TIHK Guidance on Professional Tax Practice 202210	Oct 2022	Ref Only


		中國部份

(2025.08.24)