published_or_final_version / Business Administration / Master / Master of Business Administration

by Mo Wai-bun. / Thesis (M.B.A.)--Chinese University of Hong Kong, 1990. / Bibliography: leaf 52. / ABSTRACT --- p.ii / TABLE OF CONTENTS --- p.iii / ACKNOWLEDGEMENTS --- p.v / Chapter I . --- INTRODUCTION & METHODOLOGY --- p.1 / The Scope of Inland Revenue Ordinance --- p.1 / Lialility to Profits Tax --- p.2 / "Carrying on Trade, Profession, or Business" --- p.2 / Profits Arising in or Derived from Hong Kong --- p.4 / A Conceptual Perspective of Tax Planning --- p.5 / Purpose of the Research --- p.7 / Methodology --- p.8 / Structure of the Research Report --- p.9 / Chapter II. --- THE USE OF SERVICE COMPANY FOR A PARTNERSHIP --- p.10 / Introduction --- p.10 / Purpose --- p.10 / Structure --- p.11 / Taxation --- p.13 / Operation of Banking Arrangements --- p.14 / Accounting Treatment of the Scheme --- p.15 / Determination of the Director's Salary --- p.16 / Tax Savings --- p.18 / Summary --- p.19 / Chapter III. --- REINVOICING AND THE TAXATION OF SALES PROFITS --- p.21 / Introduction --- p.21 / Background --- p.21 / The Uncertainty from Sinolink --- p.23 / The Reinvoicing Paradox --- p.24 / Tax Planning Structure of Reinvoicing Companies --- p.26 / Chapter IV. --- THE USE OF OFF-SHORE COMPANIES TO ELIMINATE PROFITS TAX ON SALES --- p.29 / Introduction --- p.29 / Background --- p.29 / Hong Kong Profits Tax Implications of Current Operations --- p.30 / A Tax Efficient Structure --- p.31 / Operation Procedures under the Proposed Structure --- p.32 / Place of Incorporation of Offshore Company --- p.35 / Jersey --- p.35 / Background --- p.35 / Incorporation --- p.36 / Taxation --- p.36 / Isle of Man --- p.36 / Background --- p.36 / Incorporation --- p.37 / Taxation --- p.37 / Implementation --- p.37 / Costs --- p.38 / Hong Kong Tax Implications of the Activities of Off-Shore Companies --- p.38 / Honf Kong Tax Implications of the Activities of HK Cos --- p.40 / PRC Implications --- p.40 / Summary --- p.41 / Chapter V. --- CONCLUSION --- p.42 / APPENDICES --- p.43 / Chapter 1 . --- Contract for Services --- p.44 / Chapter 2. --- Employment Agreement --- p.46 / Chapter 3. --- Expense Report Format --- p.51 / BIBLIOGRAPHY --- p.52

by Ko Kwok-Wai & Wong Man-Fai. / Thesis (M.B.A.)--Chinese University of Hong Kong, 1992. / Includes bibliographical references (leaves 110-113). / ABSTRACT --- p.ii / TABLE OF CONTENTS --- p.iv / ABBREVIATIONS --- p.vi / Chapter / Chapter I. --- INTRODUCTION --- p.1 / Objectives of the Study --- p.2 / Limitations of the Study --- p.3 / Methodology of the Study --- p.4 / Chapter II. --- A REVIEW OF TAX PLANNING TECHNIQUES USED IN HONG KONG COPORATIONS --- p.6 / Sourcing Profits of Hong Kong Corporation offshore --- p.7 / Structuring Receipts to be of Capital Nature --- p.17 / Increasing allowable deduction --- p.19 / Deferring the Payment of Tax --- p.25 / Diversion and Extraction of Income --- p.26 / Treaty Shopping --- p.29 / Chapter III. --- HONG KONG TAX AUTHORITY'S POLICY TOWARDS TAX PLANNING --- p.33 / Anti-avoidance Legislation --- p.33 / Tax Authorities General Attitude and Policy towards Tax Planning Activities --- p.43 / Chapter IV. --- CORPORATE MANAGEMENT'S ATTITUDE TOWARDS TAX PLANNING ACTIVITIES --- p.45 / Tax Planning in 1970's --- p.45 / Tax Planning in early 1980's --- p.46 / Tax Planning in late 1980's to 1990's --- p.47 / Chapter V. --- DEVELOPMENT OF TAX ADVISORY SERVICES IN HONG KONG --- p.50 / Tax Advisory Services in 1970's - Infant stage --- p.50 / Tax Advisory Services in early 1980's - Growth Stage --- p.51 / Tax Advisory Services in late 1980to1990's - Mature Stage --- p.52 / Chapter VI. --- SOME EMPIRICAL ANALYSIS --- p.55 / Objectives --- p.55 / Methodology --- p.55 / Limitations --- p.57 / Findings and Conclusions --- p.57 / Chapter VII. --- CONCLUSIONS --- p.70 / Future Orientation of Tax Planning Activities in Hong Kong --- p.70 / Further Comments --- p.72 / APPENDIX --- p.74 / BIBLIOGRAPHY --- p.110

This study investigates two specific types of transactions---source of profits and real property gains---in the Hong Kong tax context as well as how the structure of transactions with tax implications affects taxpayers' and stakeholders' decisions in the context of taxation management. Effective tax planning, among other factors, requires the tax planner who makes investment and financing decisions to consider not only explicit taxes but also implicit taxes [Scholes and Wolfson (SW), 1992; 2002]. This study has two main objectives. First, using 73 and 161 published legal case decisions on locality of profits and gains from real property transactions respectively, this study runs binary logit tests to examine the relative significance of the major factors contributing to judicial decisions on locality of profits and gains from real property transactions. As such, it provides business managers with empirical evidence and insightful thoughts on gaining a proper understanding of the structure of business transactions for the purposes of taxation management. Second, it extensively reviews the corporate tax structure in the Asia-Pacific region, international corporate tax research, and the implicit taxes theories, thereby providing the institutional setting for the above empirical work. The empirical results indicate that the factor, "location of services/work rendered" is exceptionally positive and significant to judicial decisions on source of profits; three factors, namely "financial ability of taxpayer", "circumstances leading to disposal", and "stated or actual intention at time of acquisition of subject property" are statistically significant to judicial decisions on gains from real property transactions. The results of both are robust to the two logit models. / Cheung Kowk Chun. / "May 2004." / Adviser: Zhaodong Jiang. / Source: Dissertation Abstracts International, Volume: 65-04, Section: A, page: 1438. / Thesis (Ph.D.)--Chinese University of Hong Kong, 2004. / Includes bibliographical references (p. 237-260). / Available also through the Internet via Current research @ Chinese University of Hong Kong under title: Taxation management and the structure of transactions evidences of source of profits and real property gains. An implicit tax perspective (China) / Electronic reproduction. Hong Kong : Chinese University of Hong Kong, [2012] System requirements: Adobe Acrobat Reader. Available via World Wide Web. / Electronic reproduction. Ann Arbor, MI : ProQuest dissertations and theses, [200-] System requirements: Adobe Acrobat Reader. Available via World Wide Web. / Electronic reproduction. Ann Arbor, MI : ProQuest Information and Learning Company, [200-] System requirements: Adobe Acrobat Reader. Available via World Wide Web. / Abstracts in English and Chinese. / School code: 1307.