2. How much should I pay for an advance ruling?
The fees payable in respect of an application for a ruling as specified under Part II of Schedule 10 of the Inland Revenue Ordinance are as follows:
| (i) for a ruling on whether profits are to be treated as chargeable to Profits Tax under section 14 of the Inland Revenue Ordinance as arising in or derived from Hong Kong | $45,000 |
| (ii) for a ruling on whether remuneration is to be treated as chargeable to Salaries Tax under section 9A of the Inland Revenue Ordinance | $15,000 |
| (iii) for any other ruling | $15,000 |
(Note: If the time spent by the Inland Revenue Department in respect of the ruling procedure is too long, additional fees may be imposed.)
The applicant has to also reimburse the Commissioner for any fees incurred for external advice, other costs and reasonable disbursements. Even if an application for ruling is withdrawn, the applicant still has to pay all of that mentioned above, subject to waiver in whole or in part of the Commissioner.
Since application fees for an advance ruling involve a considerable amount of money, it may not be cost-effective to get an advance ruling on a tax dispute that only involves a small sum of money. You are recommended to consult professional tax advisors if you wish to make an advance ruling application.
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