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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Hong Kong: Underlying Tax

(1) Documents needed to support the underlying tax claim 

The accounts showing the profits out of which the dividend was paid and the notice of assessment to profits tax showing the final liability to tax will be required by the Underlying Tax Group. Profits for the year ended 31 December 2007 are assessed in the tax year ended 31 March 2008.

The Hong Kong Inland Revenue Department form entitled ‘Profits Tax Return - Corporations Final Tax Assessment [tax year] And Provisional Payment [subsequent tax year]’ includes both the tax assessed for a tax year and a provisional payment in respect of the subsequent year, so will not support the underlying tax claim.

(2) General 

For underlying tax purposes, dividends arising from Hong Kong companies are currently treated separately to those paid by Chinese companies.