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Advance Ruling Case No. 2

1. The provisions of the Ordinance

  This ruling applies in respect of section 18E of the Inland Revenue Ordinance.


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2. Background

(a) A Ltd commenced business in Hong Kong after 1 April 1974.
(b) A Ltd has made up its accounts for each year up to 31 March.
(c) The latest set of accounts submitted by A Ltd covered the period from 1 April 1999 to 31 March 2000.
(d) A Ltd's ultimate holding company is H Ltd, a company incorporated in Japan.
(e) As a result of the "Notice of Requirement for Early Disclosure of Consolidated Financial Information" as announced by the Tokyo Stock Exchange, H Ltd has to report its consolidated financial results for the year ended 31 March by 30 June of the same year.
(f) To alleviate time pressure for consolidated reporting purposes, H Ltd has directed that A Ltd's accounting date be changed from 31 March to 31 December.

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3. The arrangement

  The subject transaction is the change of accounting year end date of A Ltd from 31 March to 31 December in 2000.

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4. The ruling

(a) The Commissioner agrees that the 9 months period from 1 April 2000 to 31 December 2000 will be accepted as the basis period of A Ltd for the year of assessment 2000/2001 under Section 18E(1)(i).
(b) The Commissioner agrees that the assessable profits of A Ltd for the year of assessment 1999/2000 will not be re-computed under Section 18E(1)(ii).

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5. The period for which the ruling applies

  This ruling applies to A Ltd for the years of assessment 1999/2000 to 2000/2001.

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6. The material assumptions in respect of a future event or any other matter made by the Commissioner

  The Commissioner has made no assumptions.

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7. Date of ruling issued

  7 February 2001.