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Departmental Interpretation And Practice Notes - No

TAX TREATMENT OF REGULATORY CAPITAL SECURITIES Inland Revenue Department hong kong Departmental Interpretation AND Practice Notes NO. 53 These Notes are issued for the information of taxpayers and their tax representatives. They contain the Department s Interpretation and practices in relation to the law as it stood at the date of publication. Taxpayers are reminded that their right of objection against the assessment and their right of appeal to the Commissioner, the Board of Review or the Court are not affected by the application of these Notes . WONG Kuen-fai Commissioner of Inland Revenue February 2017 Our web site : CONTENT Introduction Departmental Interpretation AND Practice Notes No. 53 Paragraph Relevant legislation 1 Basel III capital adequacy requirements Implementation of Basel III requirements 2 Features of regulatory capital securities 3 Tax framework for regulatory capital securities The framework 4 The main provisions 6 Regulatory capital securities Covered securities 7 Excluded securities 9 Regulatory capital securities treated as debt securities Sums treated as interest payable 11 Sums treated as chargeable profits 13 Issuer and specified connected persons Specif

TAX TREATMENT OF REGULATORY CAPITAL SECURITIES . Inland Revenue Department Hong Kong . DEPARTMENTAL INTERPRETATION AND PRACTICE NOTES . NO. 53 . These notes are issued for the information of taxpayers and their tax

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