rocket
Orbitax subscribers can now easily follow the latest COVID-19-related tax measures being implemented worldwide. New to Orbitax? Create a free account to access your dashboard and latest tax news.
News Share

The Tax Hub

Daily Tax Newsletter

Ireland-Hong Kong

Responsive image

Ireland Clarifies Taxation of Interest Paid to Hong Kong

Irish revenue has issued eBrief No. 166/18 on an update to Tax and Duty Manual Part 08-03-06, which confirms that, in certain circumstances, interest paid to Hong Kong should be exempted from tax. The update concerns a restriction on exemptions for interest paid to territories that provide for a territorial system of taxation as follows:

Territorial systems – Hong Kong

Where the relevant territory provides for a territorial system of taxation, the law of the relevant territory may charge tax on income receivable by a company by reference to such income having its source in the relevant territory, rather than by treating the company as resident for tax purposes in that relevant territory. The company may be chargeable to tax on interest payments only to the extent that such interest payments are treated as derived from a source within the relevant territory. Where such a territorial system applies to the company by which interest is receivable, that interest will not be exempt from tax under section 246(3)(h)(I) TCA 1997 or section 198(1)(c)(ii)(I) TCA 1997.

However, where:

  • such interest is paid to a company treated as resident in Hong Kong for the purposes of the double tax treaty with Ireland; and
  • the interest is subject to the full rate of corporate income tax that applies in Hong Kong, on the basis that it is treated, by virtue of the law of Hong Kong, as derived from a Hong Kong source

it will be treated by Revenue as exempted:

  1. under section 246(3)(h)(I) TCA 1997, from withholding tax; and
  2. under section 198(1)(c)(ii)(I) TCA 1997, from the charge to income tax.

Where the interest is not treated as Hong Kong source income of a Hong Kong resident company it will be subject to withholding tax and chargeable to income tax.

Powerful Tax Tools

NEW

FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.

NEW

Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.

NEW

Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.

NEW

Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.

NEW

Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.

NEW

OECD BEPS Project

Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.

NEW

Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.

NEW

Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.

NEW

Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.

NEW

Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.

NEW

Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.

NEW

Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.

NEW

VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.

NEW

NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.

NEW

Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.

NEW

Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

Crosss Border Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment Streams.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More