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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 IRO as arising in or derived from Hong Kong

$30,000

(ii) for a ruling on whether remuneration is to be treated as chargeable to salaries tax under section 9A of the IRO

$10,000

(iii) for any other ruling

$10,000

(Note: If the time spent by the IRD in respect of the ruling procedure is too long, additional fees may be imposed.)

 

As you can see from the above, the 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.

 

For more information about advance ruling, please read the Department Interpretation and Practice Notes No.31issued by the Inland Revenue Department.

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