✔ 最佳答案
In principle, the Assessable Profits (or Adjusted Loss) are the net profits (or loss) [other than profits (or loss) arising from the sale of capital assets] for the basis period, arising in or derived from Hong Kong, calculated in accordance with the provisions of Part IV of the Inland Revenue Ordinance.
The company carrying on any trade, profession or business in Hong Kong are chargeable to tax on all profits (excluding profits arising from the sale of capital assets) arising in or derived from Hong Kong from such trade, profession or business. There is therefore no distinction made between residents and non-residents.
This is a fundamental issue for the nature of the loan. If this is straightly a loan and not relating to any trade arrangement or a business of the company, the wavier of debt due to the holding company is not taxable in Hong Kong under Profits Tax - non-trade nature even there is an income reflected in the subsidiary.