Publications and Press Releases : Departmental Interpretation and Practice Notes

With effect from 1 April 2002, Departmental Interpretation and Practice Notes (DIPNs) will only be published on the IRD website. Permission is given for the downloading of these materials from the website provided that the source of the information is acknowledged and that re-dissemination or reproduction is for a non-commercial purpose.

To help keep tax representatives and other interested parties informed of current developments, IRD will advise such persons by e-mail whenever a new DIPN is issued.

For inclusion in the e-mail service mentioned above, registration is required. Please e-mail the registration to taxpf@ird.gov.hk providing the following information -

(The following Interpretation and Practice Notes are in PDF format and require the use of the Adobe(R) Acrobat(R) Reader software which can be downloaded freely at the Adobe Systems Incorporated website)

	Departmental Interpretation and Practice Notes
	Estate Duty Office Interpretation and Practice Notes
	Stamp Office Interpretation and Practice Notes

No.	Departmental Interpretation and Practice Notes	Date Issued
1.	Profits Tax Part A : Valuation of stock-in-trade and work-in-progress Part B : Ascertainment of profits and the valuation of work-in-progress (A) Building and engineering contracts (B) Property development and property investment	July 2006
2.	Profits tax Part A : Industrial building allowances Part B : Commercial buildings allowances	April 1999
3.	Profits tax - Apportionment of expenses	29 December 1989
4.	Lease premiums / Non-returnable deposits / Key or tea money / Construction fees etc.	February 2006
5.	Profits tax deductions for expenditure on - (A) Research and development (B) Technical education (C) Patent rights, etc (D) Building refurbishment (E) Prescribed fixed assets	August 2007
6.	Inland Revenue Ordinance - Provisions as to (A) Objections to the Commissioner (B) Appeals to the Board of Review (C) Appeals to the Courts	November 2006
7.	Machinery and plant - Depreciation allowances	August 2002
9.	Major deductible items under salaries tax	September 2006
10.	The charge to salaries tax	June 2007
11.	Field audit and investigation	October 2007
12.	Commissions, rebates and discounts	September 2001
13.	Profits tax - Taxation of interest received	December 2004
13A.	Profits tax - Deductibility of interest expense	December 2004
14.	Property tax	February 2005
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	January 2006
16.	Salaries tax - Taxation of fringe benefits	October 2003
17.	The taxation of persons chargeable to profits tax on behalf of non-residents	January 2005
18.	Assessment of individuals under salaries tax and personal assessment	January 2005
19.	The agreement between the United States of America and Hong Kong in respect of the taxation of shipping profits	28 September 1989
20.	Unit trusts, mutual fund corporations and similar collective investment schemes	June 1998
21.	Locality of profits	March 1998
22.	Computation of assessable profits from cinematograph films, patents, trademarks, etc.	January 2005
23.	Recognized retirement schemes	September 2006
24.	Service company "Type II" arrangements - Profits tax	August 1995
25.	Service company "Type I" arrangements - Salaries tax	August 1995
26.	Specified securities for the purposes of section 15E of the Inland Revenue Ordinance	August 1996
27.	Stock borrowing and lending	November 1996
28.	Profits tax - Deductibility of foreign taxes	July 1997
29.	Tax relations between the Hong Kong Special Administrative Region and the People's Republic of China	August 1997
30.	Profits tax : Section 20AA Persons not treated as agents	August 1998
31.	Advance rulings	April 1998
32.	Arrangement between the Mainland of China and the Hong Kong Special Administrative Region for the avoidance of double taxation on income	June 1998
33.	Insurance agents	June 1998
34.	Exemption from profits tax (interest income) Order 1998	December 2004
35.	Concessionary deductions : Sections 26E and 26F Home loan interest	May 2007
36.	Concessionary deductions : Section 26D Elderly residential care expenses	January 2000
37.	Concessionary deductions : Section 26C Approved charitable donations	September 2006
38.	Salaries tax - Employee share-based benefits	March 2008
39.	Profits tax - Treatment of electronic commerce	July 2001
40.	Profits tax - Prepaid or deferred revenue expenses	October 2002
41.	Salaries tax - Taxation of holiday journey benefits	August 2003
42.	Profits tax - Part A : Taxation on financial instruments Part B : Taxation of foreign exchange differences	November 2005
43.	Profits tax - Profits tax exemption for offshore funds	September 2006
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	April 2007

No.	Estate Duty Office Interpretation and Practice Notes	Date issued
1.	Controlled companies provisions under the Estate Duty Ordinance (Cap.111)	21 December 2000

No.	Stamp Office Interpretation and Practice Notes	Date issued
1.	Stamping of agreements for sale and purchase of residential property	August 2006
2.	Relief for stock borrowing and lending transactions Part A - Commercial stock loans	25 January 2000
3.	Deemed consideration under section 24 of the Stamp Duty Ordinance, Cap.117	September 1998
4.	Deemed sale and purchase under section 19(1E) of the Stamp Duty Ordinance, Cap.117	25 January 2000