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How Hong Kong companies get prepared for the challenges under the new tax treaty benefit claim procedures in China

This seminar will be opened for enrolment on 22 January 2016 at 11:00am. The "Login to Enrol" button is NOT available before 22 January at 11:00am.

Event Details:

Speakers :

Mr Kenneth WONG, Tax Partner, International Tax and Mergers and Acquisition Group, PwC

Ms Rebecca WONG, Senior Manager, Hong Kong, China Tax and Business Advisory Services Group, PwC

Mr Nathan YICK, Manager, International Tax and Mergers and Acquisition Group, PwC

Date : 18 February 2016 (Thursday)

Time : 7:00pm - 9:00pm (Registration starts at 6:30pm)

Venue : Ming Hua Hall, 4/F., St. James' Settlement, No. 85 Stone Nullah Lane, Wanchai, Hong Kong (Please click here to see the map)

Language : Cantonese (no simultaneous translation)

CPD Credit : 2 hours

Fee : HK$100-

About the Seminar:

Hong Kong has always been a common investment platform, through the use of special purpose vehicles (SPVs), for investment into China because of the geographical/commercial reasons and also the potential enjoyment of benefits under Hong Kong-China double tax treaty (e.g. reduced withholding tax rate on dividend and exemption from capital gain tax).

However, in most of the cases, the Hong Kong SPVs are pure investment holding companies lacking sufficient commercial substances. With the recent development and changes in the China's domestic tax requirement (e.g. Public Notices “PN” 7 and 60) and Base Erosion of Profit Shifting in the international tax context, proving commercial substance in the Hong Kong SPVs has become a necessity and more important than ever in order to enjoy the double tax treaty benefit and prevent from potential challenges from tax authorities.

In this seminar, the speakers will share insights of below:

- Snapshots of the key global trend in examining the ‘substance’ in the context of tax treaty

- Introduction of the recent regulatory changes in China (PN 7 - indirect transfer of Chinese investments; and PN60/SAT notice 128 - self assessment mechanism and new procedures for tax treaty application) and the relevant impacts to the taxpayers

- Our observation on the Hong Kong Inland Revenue Department's recent practice in examining Hong Kong Tax Residency Certificate (HKTRC) applications

- Key considerations in building ‘substance’ from both technical and practical perspectives

- Sharing of recent real life cases on building substance in SPVs to enhance the chance of getting HKTRC and treaty benefits

- Relationship between having substance and exchange of information under tax treaty

About the Speakers:

Mr Kenneth WONG

Mr Kenneth WONG is a tax partner in the International Tax and Mergers and Acquisition group of PricewaterhouseCoopers with over 18 years of experience in Hong Kong and international tax consulting and planning work, including corporate structuring, mergers and acquisition, tax due diligence, IPOs, etc. In addition, he has significant experience in assisting clients on outbound and inbound investment from and into China as well as the application of tax treaty benefits and Hong Kong Tax Residency Certificate for future exit and profits repatriation.

Kenneth is a Committee Member and also the Co-Chairman of the Tax Sub-committee of The Association of Chartered Certified Accountants, the President of Institute of Accountants Exchange and a Member of The Hong Kong Institute of Certified Public Accountants and The Taxation Institute of Hong Kong.

Ms Rebecca WONG

Ms Rebecca WONG is a Senior Manager in the Hong Kong, China Tax and Business Advisory Services group of PricewaterhouseCoopers, Hong Kong. She has over 8 years professional experience in providing comprehensive Hong Kong and PRC tax consulting services, tax compliance and tax treaty application services to various multinational, Hong Kong and China domestic companies. She has assisted clients in dealing with the Hong Kong Inland Revenue Department and China tax authorities.

Mr Nathan YICK

Mr Nathan YICK is a manager in the International Tax and Mergers and Acquisition group of PricewaterhouseCoopers. He has extensive experience in providing tax consulting services to local, regional, multi-national and listed companies. He also assisted many clients in application of Hong Kong Tax Residency Certificate for claiming the double tax treaty benefit. Nathan is a member of Hong Kong Institute of Certified Public Accountants.

CPD Hours:

Completed CPD hours will be granted to attendees who have attended a full session of seminar. For those who have not attended full session, the number of CPD hours will be discounted accordingly. For the exact recognition of the CPD hours, please check with the respective Institute or Association.

Bad Weather Arrangement:

This event may be cancelled or re-scheduled when typhoon no.8 or black rainstorm warning is hoisted. Please refer to our website for the arrangement.


Accounting Development Foundation Limited (ADF)

CPD Requirements: Our seminars can fulfil CPD requirements. As professional bodies would not formally endorse the seminars we provide, it does not mean that the events we organize do not meet the CPD purpose. Registrants should note that you are responsible for determining whether our seminars or any event satisfy your CPD requirements i.e. that the training you receive are of appropriate standard and relevance to your maintaining and enhancing the technical knowledge and professional expertise. If necessary, please check with your respective professional body before registering our seminars. ADF does not warrant that the attendance of our seminars or events would automatically be recognized by the respective professional bodies as fulfilling your CPD requirements.


- This seminar will be opened for enrolment on 22 January 2016 at 11:00am. The "Login to Enrol" button is NOT available before 22 January at 11:00am.

- Only ADF Friends and online enrolment will be accepted. Please make sure that you have registered as an ADF Friend and have your ADF Friend account activated before enrolment.

- You may also click here to read the enrolment procedures.

- Acceptance will be on a first-come-first-served basis.

- The online enrolment is closed. Please email to for any enquiry.

Our server may experience high volume of traffic and cannot process your registration immediately. We are sorry for any inconvenience caused and your kind understanding is highly appreciated.

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