FINANCIAL ACCOUNTING
FINANCIAL ACCOUNTING
10th Edition
ISBN: 9781259964947
Author: Libby
Publisher: MCG
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It is talking about Hong Kong Tax, Special Business, Profit Tax Computation of Financial instituition, please explain what is  DIPN 21 and its related two concepts, "Initiation" and "funding" with example, and explain the two drafts below.  

DIPN 21 for Financial Institutions
▸ Loan interest income
Depends on two factors only: (1) Initiation; and (2) Funding
Initiation
Efforts in obtain the business including solicitation, negotiation and
structuring of loans
⚫ If wish to claim offshore, HK FI must prove the participation of the loan is
the direct result of the activities done by an associate party outside HK
Funding
Provision of the money for the loan
If wish to claim offshore, (1) HK FI must prove it has no authority to fund
the loan; and (2) documentary evidence showing the fund is provided by
an offshore associate directly
DIPN 21 for Financial Institutions
▸ Loan interest income
。 Tax treatment on interest income from offshore loans:
Initiation
Outside HK
Funding
Outside HK
Hong Kong
Hong Kong
Tax treatment
100% non-taxable
100% taxable
Outside HK
Hong Kong
50% taxable
Hong Kong
Outside HK
50% taxable
。 Tax treatment on interest income from onshore loans
Fully taxable
Exemption Order is NOT applicable
83
84
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Transcribed Image Text:DIPN 21 for Financial Institutions ▸ Loan interest income Depends on two factors only: (1) Initiation; and (2) Funding Initiation Efforts in obtain the business including solicitation, negotiation and structuring of loans ⚫ If wish to claim offshore, HK FI must prove the participation of the loan is the direct result of the activities done by an associate party outside HK Funding Provision of the money for the loan If wish to claim offshore, (1) HK FI must prove it has no authority to fund the loan; and (2) documentary evidence showing the fund is provided by an offshore associate directly DIPN 21 for Financial Institutions ▸ Loan interest income 。 Tax treatment on interest income from offshore loans: Initiation Outside HK Funding Outside HK Hong Kong Hong Kong Tax treatment 100% non-taxable 100% taxable Outside HK Hong Kong 50% taxable Hong Kong Outside HK 50% taxable 。 Tax treatment on interest income from onshore loans Fully taxable Exemption Order is NOT applicable 83 84
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