Transcription of Departmental Interpretation And Practice Notes - No
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Departmental Interpretation And Practice Notes - No
Inland Revenue Department The Government of the Hong Kong Special Administrative Region of the People's Republic of China Departmental Interpretation AND Practice Notes . NO. 52. TAXATION OF CORPORATE TREASURY ACTIVITY. 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 .
from and lends money to its associated corporations regularly as a business with a view to earning an interest margin. The deduction rule in section 16(2)(g) would not apply to a corporation which borrows and lends money in isolated transactions. Whether a coron an intra-group poration is carrying financing business is a question of fact.
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