✔ 最佳答案
Condition 1 & 3 will never be chargable for HK tax accordingly to S.14 of IRO and DIPN 21 of IRD.
Condition 2 will only be chargable for HK tax if the acquisition and sale of the saild Shares has been treated as trading nature according to the 6 badges of trade: (1) the subject matter of the realization (2) the length of the period of ownership (3) the frequency or number of similar transactions (4) supplementary work in connection with the subject matter (5) the circumstances leading to the realization and (6) the motive. However, it is unlikely to be subject for HK tax accordingly to your information provided.
2011-07-27 11:59:35 補充:
Provision of credit test can apply to rental income derived from an overseas property? Never. Please be advised that in no circumstance would the rental income derived from an overseas property be chargable in HK tax.