11288B Request under section 88B of the Inland Revenue Ordinance (Cap 112) for a Notice of No Object 2025

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Section 50AAK aims to prevent under-attribution of income or over-attribution of loss to a non-Hong Kong resident persons permanent establishment in Hong Kong. It is not to be used to achieve double deduction or double non-taxation.
Section 14 of the Inland Revenue Ordinance (the Ordinance) contains the main charging provision for profits tax. In short, profits tax is charged on a person in respect of the persons assessable profits arising in or derived from Hong Kong from a trade, profession or business carried on by the person in Hong Kong.
Section 88 of the Inland Revenue Ordinance (Cap 112) (the IRO) provides that a charity is exempt from profits tax subject to certain conditions to be fulfilled in relation to the trade or business carried on by the charity concerned.
Section 17(1)(c) of the Inland Revenue Ordinance (Cap. 112) (IRO) provides that any expenditure of a capital nature shall not be deducted for the purpose of ascertaining profits in respect of which a person is chargeable to profits tax.
7. Section 87 of the IRO provides that the Chief Executive in Council may by order exempt any person, office or institution from payment of the whole or any portion of any tax chargeable under the IRO.
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