Raymond Yeung Tax Consultant * former Assessor of IRD

飛鴻稅務顧問 * 前稅局評稅主任 楊輝洪 主理

yeungfhr@yahoo.com.hk * R 1/F Rose Garden, 23 Hang Tau, Sheung Shui

Tel:  94735846 * 會面可在九龍塘又一城 * 稅務顧問收費每小時$400

 

IRD's Tax Ruling vis-a-vis RYTC's advice

 

IRD's Tax Ruling

Raymond Yeung's Advice

There are a lot of situations in which the Revenue refuses to make a ruling. See previous page.

No such restrictions.

The initial fee is HK$30,000 for a ruling on source of profit under Section 14 of IRO and HK$10,000 for other cases. It may even cost more if they spend more time than a standard case.

No charge on oral advice (please phone 94735846); HK$400 for most cases in which writing work is involved. For further details, please see Fee Scale

The Revenue will give you an initial reply within 6 weeks. Mind that it is a reply, not necessarily a decision.  

I will give you my writing work within 5 working days after receiving your payment.

The ruling will be binding on the Revenue until it is withdrawn. But this can be a demerit to an applicant because with such binding, the Revenue,  because of its bureaucratic instinct, tends to make conservative ruling unfavorable to the applicant. Worse still, once a unfavorable ruling is made, the Revenue's assessing officers must follow it --- then if the applicant proceeds to carry out the transaction, he will certainly get an assessment based on the unfavorable ruling. In that case, if he disagrees to the ruling, he will have to pursue the matter in accordance with the objection procedure which is expensive, troublesome and time-consuming.

Of course, my advice does not bind the Revenue. But it is because of this can you avoid the demerits of the Revenue's tax ruling - see opposite column. 

I pledge to give you my best advice. See my performance pledge and resume.  I am sure with my advice you can make your best decision. 

 

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Raymond Yeung 為你提供  香港稅須知實用稅務課程HK Taxation  私人補習

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