Taxation Law Research Programme (TLRP)
Convenor: Professor Richard Cullen
Professor Richard Cullen was previously a Professor in the Department of Business Law and Taxation at Monash University in Melbourne, Australia. He completed his LLB at Melbourne University Law School in 1982 and his doctorate at Osgoode Hall Law School in Canada in 1986. He is admitted to practise law in Victoria, Hong Kong, England and Wales and worked with a major law firm in Melbourne for two years. Before coming to tertiary teaching, Richard worked as a manager with the Australian government’s Commonwealth Scientific and Industrial Research Organisation (CSIRO).
The Taxation Law Research Programme (TLRP) was established within the HKU Faculty of Law’s Asian Institute of International Financial Law (AIIFL) in 2007 to foster research on Hong Kong, mainland China, Asian and international taxation law and related policy areas as well as to provide public sector, capacity building consultancy services on tax policy development and tax system operation.
TLRP Tax Comments (TTC) – Working Paper Series (WPS)
The objective of the TTC-WPS is to allow for the publication of papers which, although completed in draft form, are undergoing further revision and development.
Working Paper No 1:
DTA Pensions Clause Fails Preservation, Portability and Long Duration Capital Formation Tests
Ross Smith
TLRP Tax Comments (TTC) provides an online publication platform for stimulating Tax Law & Policy articles and notes.
Tax Comments No. 7
CONSUMPTION TAX REFORM IN AMERICA: UNDER THE RADAR – BUT UNDERWAY
Professor Richard Cullen
Tax Comments No. 6
HONG KONG’S INVOLVEMENT WITH INTERNATIONAL TAX REFORM: WHAT’S THE ‘BEPS’?
Professor Adrian Sawyer
Tax Comments No. 5
QUESTION & ANSWER SESSION ON:
HONG KONG’S COMPREHENSIVE DOUBLE TAX AGREEMENT (CDTA) NETWORK
Wilson Chow
Tax Comments No 4:
AN UPDATE ON HONG KONG’S EXCHANGE OF INFORMATION DEVELOPMENTS AND ENGAGING WITH BEPS
Adrian Sawyer
Comments No 3:
REAL ESTATE PRICE INFLATION: LESSONS FROM HONG KONG
Richard Cullen
Tax Comments No 2:
LAND REVENUE AND THE CHINESE DREAM
Richard Cullen
Tax Comments No 1:
THE MAKING OF TAX LAW IN CHINA – DOES IT COMPLY WITH RULE OF LAW PRINCIPLES
Agnes LEE, Sui Ping
TTC Submissions
We welcome further submissions for consideration for publication at TTC. Submissions need to be in English and, broadly, need to address a significant aspect, in a research-based manner, of Tax Law and/or Tax Policy.
We expect that most publications appearing will focus on the HKSAR and Mainland systems. International Tax comments, especially where there is a Greater China connection, are also welcome. Submissions outside of these parameters can be considered on a case-by-case basis.
Intensive course
[POSTPONED] An Introduction to the OECD Global Minimum Tax (Pillar 2) Taxation – Flyer
An Introduction to International Taxation (14-16 June 2019) – Flyer
An Introduction to International Taxation (8-10 June 2018) – Flyer
An Introduction to International Taxation (9-11 June 2017) – Flyer
An Introduction to International Taxation (3-5 June 2016) – Flyer
An Introduction to International Taxation (1-3 June 2012) – Flyer
Upcoming Event
International Tax Framework for Investment, Wealth and Philanthropy Hubs (10 July 2025)
Past Events
Taxation and Climate Change (9 April 2025)
Professor Archie Parnell, Law School, Jindal Global University (India)
The Global Minimum Taxation (GloBE) – Implementation in Asia-Pacific, Europe and the Middle East and Impact on Tax Incentives, Tax Systems and Tax Competition – Is Hong Kong Prepared? (10 October 2024)
Professor Dr Martin Wenz, University of Liechtenstein
The Pillar Two Model Rules: Ensuring Minimum Taxation for Multinational Enterprises (25 September 2024)
Professor Dr Stefano Grilli, Adjunct Professor of International Tax Law, University of Milan Bicocca and Partner, Deloitte (Milan)
United Nations Role in International Tax Order: Past, Present and Future (28 February 2024)
Dr M Ashfaq Ahmed, Pakistan Inland Revenue Service (IRS) Officer
Strategic Incentives for Adopting the Global Minimum Tax (26 January 2024)
Professor Wei CUI, Peter A. Allard School of Law, University of British Columbia
Should Hong Kong Follow New Zealand’s Decision to Implement a Digital Services Tax? (1 November 2023)
Professor Adrian Sawyer, University of Canterbury
Book Talk: The Administrative Foundations of the Chinese Fiscal State (14 April 2023)
Professor Wei CUI, Peter A. Allard School of Law, University of British Columbia
The Public Revenue Regime in Hong Kong: Land & Housing (13 April 2023)
Professor Richard Cullen
Global Minimum Tax Reform and the Future of Tax Competition (15 March 2023)
Jeremy Jingxian Chen, PhD Student of International Tax Law, Wuhan University
Global Minimum Tax Reform and China (23 November 2022)
Professor Xiaojing CUI, Wuhan University School of Law
The Changing Landscape of Inbound and Outbound Investment to and from Hong Kong: Taxation Implications for Investors and Corporate Entities (25 August 2022)
Dr Sarah Hinchliffe, School of Professional Accountancy, Long Island University
The Future of Tax Jurisdiction (22 June 2022)
Professor Miranda Stewart, Melbourne Law School, University of Melbourne
Peter Willoughby Memorial Lecture
China’s Rising (and the United States’ Declining) Influence on Global Tax Governance? Some Observations (3 March 2022)
Professor Jinyan Li, Professor of Tax Law, Osgoode Hall Law School, York University, Canada
Creating Equitable Tax Systems: Challenges Posed by Financial Markets (17 February 2022)
James Fok, Author, Financial Cold War
Hong Kong and BEPS 2.0 (30 November 2021)
Professor Adrian Sawyer, Professor of Taxation, UC Business School, University of Canterbury
A Multilateral Agreement on Carbon Pricing and Implications for Developing Countries (17 November 2021)
Dr Yan Xu, Scientia Associate Professor of Tax Law, UNSW Business School
Digital Assets in Hong Kong: What are They and How are They Taxed (31 May 2021)
Dr Oriol Caudevilla, FinTech Advisor
Tax Residency, Investment Opportunities Retirement Considerations for the Expat (9 December 2020)
Dr Sarah Hinchliffe, Associate Professor, School of Professional Accountancy, Long Island University
BEPS 2.0 (22 November 2019)
Professor Judith Freedman, CBE, Professor of Taxation Law and Policy, University of Oxford and Professor Adrian Sawyer, Professor of Taxation, University of Canterbury
Blockchain, Big Data and International Tax Compliance (19 June 2019)
Dr Sarah Hinchliffe, Assistant Professor of Tax and Accounting, University of Akron
Investments, Pensions, and Strategic Planning – Taxation Opportunities and Traps for Hong Kong Residents and Expats (12 June 2018)
Dr Sarah Hinchliffe, Assistant Professor of Tax and Accounting, University of Akron
Expats & Professionals in Greater China: Retirement Planning Opportunities & Challenges (13 June 2017)
Sarah Hinchliffe, Assistant Professor of Tax and Accounting, University of Akron
Hong Kong’s Involvement with International Tax Reform: What’s the ‘BEPS’? (30 March 2017)
Professor Adrian Sawyer, University of Canterbury
An Update on Hong Kong’s Exchange of Information Developments and Engaging with BEPS (18 November 2016)
Professor Adrian Sawyer, University of Canterbury
Are Trusts Still a Strategic Investment Vehicle for Clients? (7 June 2016)
Sarah Hinchliffe, Visiting Professor, College of William and Mary Mason School of Business
Tax Concessions Granted to Charities – an International Comparison (1 April 2016)
Dr Fiona Martin, School of Taxation and Business Law, UNSW, Sydney
Transnational Tax Law: Fiction or Reality, Future or Now? (23 March 2016)
Professor Miranda Stewart, Director, Tax and Transfer Policy Institute, The Australian National University
The Taxation of Trusts in Hong Kong (2 December 2015)
Stefano Mariani, Registered Foreign Lawyer, Deacons, Hong Kong
Tax Hot Topics Affecting Dual Residents (20 August 2015)
Sarah Hinchliffe, Visiting Professor of Law, College of William and Mary Mason School of Business
Legislation by Press Release: Hong Kong’s New Stamp Duties – Why & How They Work (8 January 2015)
Jianlin Chen, Assistant Law Professor, Faculty of Law, The University of Hong Kong
Legal Valuation in Chinese Tax Law (5 November 2014)
Professor Xiaoqiang Yang, Professor of Tax Law, Sun Yat-sen University School of Law, Director, Research Center for Taxation & Financial and Tax Law, Sun Yat-sen University
Taxation and Residency Requirements in Hong Kong, Australia, the United Kingdom and the United States – An International Update in 2014 for Individuals, and Corporate Entities (12 June 2014)
Sarah Hinchliffe, Visiting Professor of Law, William and Mary Law School
TLRP Special Joint Seminar
From Felixstowe to Hong Kong and Taxation of International Sports Stars and Entertainers (18 December 2014)
Philip Baker QC, Field Court Tax Chambers, London and Patrick Way QC, Field Court Tax Chambers, London
TLRP Special Lecture Series
Business Tax: Public Debate and Future Trends (24 March 2014)
Professor Judith Freedman, CBE, Pinsent Masons Professor of Taxation Law University of Oxford and and Director of Legal Research, Oxford University Centre for Business Taxation
TLRP International Conference
RENOVATING THE HONG KONG REVENUE REGIME: THE LOCAL, CROSS-BORDER & INTERNATIONAL CONTEXTS (31 October 2015)
THE EUROPEAN UNION AND GREATER CHINA: UNDERSTANDING THE FUNDAMENTALS OF THE NEW TAXATION RELATIONSHIP (25 February 2012)
GREEN TAXATION IN EAST ASIA: PROBLEMS AND PROSPECTS (29 January 2010)
Publications
Dongmei Qiu (Doreen) & Richard Cullen
Green Taxation in East Asia
Book of the 2nd TLRP International Conference
Intro Pages and Index – free to download from Elgaronline.com at: http://www.elgaronline.com/abstract/9781849803007.xml
Richard Cullen, Jefferson VanderWolk and Yan Xu (Contributing Editors)
Edward Elgar Cheltenham 2011
TLRP Newsletters
TLRP Special Newsletter – TLRP Tax Comments
The Taxation Law Research Programme (TLRP) was established within the HKU Faculty of Law’s Asian Institute of International Financial Law (AIIFL) in 2007. The Foundation Members of the TLRP were:
It is particularly appropriate that the TLRP has been established within the Faculty of Law and based within AIIFL. It was the late Professor Peter Willoughby who established serious academic tax research in Hong Kong, after he commenced work with the Facutly in 1973. Peter is also remembered as a pioneer of legal education in Hong Kong, and is thought of fondly by both colleagues and students. As the University website notes:
The Peter Willoughby Memorial Fund was established in 2000 to sponsor a memorial lecture in memory of the late Professor Peter Willoughby and his invaluable contribution to the Faculty of Law and legal education in Hong Kong.
The tradition of academic research with respect to Tax Law has remained especially strong within the Faculty for around three decades. Professor Andrew Halkyard has worked in this field in Hong Kong, initially with Peter Willoughby, since 1985 and is the author of the Hong Kong Encyclopaedia of Taxation (a looseleaf 4 volume practioners’ work, with Wilson Chow and Susan Leung). Andrew and Wilson have been active with AIIFL since its foundation in 1999. Other key contributors over the years have been Michael Olesnicky and Jeff VanderWolk, both of whom have written extensively on Hong Kong Tax Law. Michael was with the Faculty from 1982 to 1988. Jeff was with the Faculty from 1991 to 1994. Both Michael and Jeff remain leading commentators on Taxation Law in Hong Kong and in Mainland China. They both still regularly write on Hong Kong, regional, and international tax issues. Since its foundation in 1999, AIIFL has hosted a number of academics dealing with taxation related issues, and taxation law and policy is one of our five core research areas. As one of the leading commercial, corporate and financial law and policy academic research centres in the region, AIIFL is committed to supporting research in taxation law and policy and providing active support for the development of the TLRP. In 2006 , Professor Richard Cullen joined the Faculty. Richard, who is also a Public Law expert, has written on and taught Tax Law in both Hong Kong and Australia. His recent work has looked at the relationship between the development of the Hong Kong Revenue Regime and the development of its political structure and the attitudes of Hong Kong residents towards the HKSAR Tax System. Richard has also been an active AIIFL Fellow since joining HKU.
The TLRP appointed its first Post Doctoral Fellow (PDF) in 2009. Dr XU, Yan was appointed for 3 years as a PDF in Chinese Tax Law and Tax Policy at that time. Her research interests include: Taxation and Constitutionalism in China; Green Taxation in China; and VAT Reform in China. In 2012, Dr Xu (who retains close links with the TLRP) became an Assistant Professor specializing in Tax Law at the Faculty of Law of the Chinese University of Hong Kong.
Dr Doreen QIU, Dongmei was appointed as the second TLRP Post Doctoral Fellow in mid-July 2012. During her time at HKU, she was involved in: (1) research and writing related to PRC & International Tax Law & Policy; (2) working as part of the TLRP Research Team; (3) TLRP Seminars & Conferences; and (4) acting as TLRP key liaison person for engaging with Tax Law and Policy Scholars in Mainland China. Doreen has returned to Xiamen University (XMU) where she is now an Associate Professor. We are sorry to lose her but wish her all the very best in Xiamen. We look forward to our continuing research cooperation with XMU related to Tax Law & Policy.
In 2016, the TLRP welcomed its third PDF, when Dr. Jingyi Wang took over from Dr. Doreen Qiu. Jingyi earned her PhD from King’s College London. She also holds an LLM from King’s College London and an LLB from the East China University of Political Science and Law. As with the first two TLRP PDFs, Jingyi Wang has researched and published widely. Her article, “The Chinese approach to transfer pricing: problems faced and paths to improvement” was published in the British Tax Review in 2016, one of the leading international tax journals. She also has published articles in Australian Tax Forum, the International Transfer Pricing Journal, the Hong Kong Law Jornal and the Company Lawyer. In mid-2017, Jingyi moved on to take up a position as a Research and Teaching PDF at the School of Transnational Law, Peking University Shenzhen Graduate School. Once again, we were sorry to lose her. We know she will do very well in her new position and we look forward to similar, ongoing research cooperation to that which we have maintained with Professor Xu and Professor Qiu.
TLRP OBJECTIVES
- To foster research, including comparative research, on Hong Kong, Mainland, Asian and International Taxation Law and related policy areas.
- To explore the Public Law as well as the Private Law dimensions of Tax Policy and operating taxation systems.
- To establish research collaboration links with other taxation research institutes internationally (International Tax Research Network [sponsored by the OECD] and the School of Taxation and Business Law at UNSW, being examples) and with universities with which HKU has strong collaborative links in the taxation field including, the University of Western Australia and the National University of Singapore.
- To engage in collaborative research projects with staff in other institutions in Hong Kong (and abroad) and with research-minded persons in the private sector.
- To seek funding, as appropriate, through research grants and other sources, to undertake relevant Tax Law research projects.
- To provide public sector, capacity building consultancy services on Tax Policy development and tax system operation.
- To conduct lectures / workshops / seminars / conferences focusing on Tax Law research.
- To run major Tax Law Conferences in Hong Kong on a regular basis (a number of these have been held over almost two decades – some of which gave rise to major publications).