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Advance Ruling Cases
Rulings are published for general reference
only. Caution should be exercised in relying upon the rulings.
Reference can only be made to a ruling if the facts are identical
to the proposed transactions. To that end it should be borne
in mind that similar transactions often have different facts.
If there are any doubts as to the similarity of the proposed
transactions the taxpayer should request a ruling. Caution
should also be exercised to ensure that the relevant provisions
of the Ordinance or the relevant case law interpretation and
practice of those provisions have not changed as the Inland
Revenue Department is bound to apply the current taxation
law. Similarly, a ruling may no longer be appropriate if an
administrative practice outlined therein turns out to be used
as a tax avoidance device.
In order to protect taxpayer confidentiality, the Department
will edit the selected rulings prior to publication. Accordingly,
all information that may enable identification of the taxpayer
will be removed from the edited version.
The Department will not update the rulings published on the
website to reflect any subsequent changes of the tax law. |