安徽HKICPA考生不要犹豫，看看这道CASE QUESTIONS你是否做得出

　　没有付出，哪里来的收获？没有考前的多加练习，哪里来的出色成绩？安徽HKICPA考生不要犹豫，看看这道CASE QUESTIONS你是否做得出吧！

　　SECTION A – CASE QUESTIONS  (Total: 50 marks)
 

　　Answer ALL of the following questions.  Marks will be awarded for logical argumentation and appropriate presentation of the answers.
 

　　Happy Inc. which is not carrying on business in Hong Kong, has two wholly owned subsidiaries in Hong Kong: (1) Happy Trading Ltd. (“HTL”) which is responsible for co-ordinating group sales and marketing activities in the Asia Pacific region and (2) Happy Properties Ltd. (“HPL”) which was set up as an investment holding company to hold the group’s office premises, warehouses and car parks in Hong Kong.
 

　　As part of the group’s expansion plan in Asia, Happy Inc. is considering the following:
 

　　Happy Inc. would like to acquire a 50% interest in one of its Hong Kong suppliers, Cheerful Manufacturing Ltd. (“CML”).  CML has a manufacturing plant in China which it operates under a processing agreement with a PRC party (“PRC Plant”).  All the finished goods are sold exclusively to HTL.
 

　　Currently, Happy Inc. has manufacturing subsidiaries in Vietnam, Thailand and Indonesia.  It has also established two wholly foreign owned enterprises in China producing goods exclusively for export to Europe and North America.
 

　　Happy Inc. has a research centre in Europe specialising in developing technology and manufacturing processes for use in the group’s production plants.
 

　　Happy Group would like to set up a subsidiary in Singapore (“Singco”) to focus on sales and marketing activities in south-east Asia.  HTL will then concentrate on Hong Kong and northern Asia markets (including Korea and Japan).
 

　　Question   (50 marks – approximately 90 minutes)
 

　　You have been asked to attend a meeting with management to discuss the above business plans and in particular to address any Hong Kong tax matters.
 

　　You were asked to comment on the following during the meeting:
 

　　(a) (i) the Stamp Duty implications of acquiring the 50% interest in CML; and (5 marks)
 

　　(ii) the Profits Tax and reporting issues which they need to consider when acquiring CML. (25 marks)
 

　　(b) Happy Inc. would like to license its technology and know-how to CML for use in the manufacturing plant in China and would like to confirm the Hong Kong tax implications for Happy Inc. (5 marks)
 

　　(c) The Hong Kong tax exposure for Singco, if any. (5 marks)
 

　　(d) HTL acquired a property two years ago for use as residential quarter for its general manager.  Management would like to transfer this property to HPL. (10 marks)
 

　　高顿网校小编为HKICPA考生介绍香港景点：挪亚方舟

　　景点地址：香港新界马湾珀欣路33号

　　景点主题：主题体验

　　相传中国的“船”字，也因为记载这事迹而成。船字左边为“舟”，右边为“八”和“口”，寓意挪亚一家八口，中国人将挪亚一家八口登上方舟而脱险之事成为“船”。远古的挪亚方舟，今日在香港再次呈现！