Abstract: The Hong Kong Special Administrative Region (HKSAR) implemented automatic exchange of information (AEOI) with the Inland Revenue (Amendment) (No. 3) Ordinance 2016 coming into effect on 30 June 2016. This development is the latest phase in the reform of the HKSAR’s exchange of information capability. AEOI follows earlier legislative reform to permit the HKSAR to enter into tax information exchange agreements (TIEAs), and the signing of a Model 2 intergovernmental agreement (IGA) under the United States’ (US’s) Foreign Account Tax Compliance Act (FATCA). The HKSAR is also actively engaged in the G20/OECD’s Base Erosion and Profit Shifting (BEPS) initiative, becoming an Associate member in order to facilitate implementation of the relevant BEPS Action Plans in both the HKSAR and internationally. This paper briefly reviews the historical developments in information exchange in the HKSAR, focussing on the implications of AOEI and BEPS developments, with some thoughts as to what the future may look like for businesses operating in the HKSAR.

This paper by Professor Adrian Sawyer Professor Adrian Sawyer Professor of Taxation in the UC Business School, University of Canterbury AIIFL Profile › can be downloaded: here .