IRD Tax Investigation & Field Audit Guide (Hong Kong)

Practical hub on IRD enquiries, field audits, investigations, section 82A additional tax and illustrative court cases — with links to our Insights.

When the Inland Revenue Department (IRD) writes — a desk query, a field-audit appointment, or a letter signalling a tax investigation — stay calm, keep the original letter and all records, and reply in writing by the stated deadline. This page gathers VCL’s recent Insights on IRD enquiries, field audits, investigations, additional tax and illustrative cases in one place.

Hong Kong’s desk audit, field audit and investigation framework is described in Departmental Interpretation and Practice Notes No. 11 (DIPN 11). After a field audit or investigation is settled, section 82A additional tax under the Inland Revenue Ordinance may arise; written representations are usually allowed not less than 21 days. Everything here is general information, not advice on your facts.

First practical steps (overview)

  • Check the letterhead, file reference and reply deadline; scan or photocopy the whole document
  • Do not destroy or alter books, bank statements, invoices or emails; nominate one contact for IRD correspondence
  • Clarify whether it is an enquiry, desk audit, field audit or investigation before scoping documents and interview prep
  • If additional tax or penalties are proposed, diary the representation deadline and gather mitigating facts

Featured Insights

Related tools and services

Other tax updates (optional)

Related IRD topics outside the investigation focus: six CDTA Orders gazetted · Pillar Two Portal top-up returns · ‘M’ code profits tax extension.

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Frequently asked questions

When must a new Hong Kong company file tax returns?

A Profits Tax return is commonly issued around 18 months after incorporation. Unless an extension is granted, file within the stated deadline. The first accounting period may be up to about 18 months; later periods are usually 12 months.

What tax does a Hong Kong company pay each year?

Trading companies are primarily concerned with Profits Tax (confirm current rates/two-tier rules with IRD). No assessable profits generally means no Profits Tax payable, but filing obligations may still exist.

Who prints Hong Kong company invoices?

Unlike Mainland China fapiao practice, Hong Kong invoices are typically prepared by the company itself and authenticated with company chop/authorised signature.

When is a company’s year-end?

Common year-ends are 31 March or 31 December. The first accounting period can be up to about 18 months.

FAQs — Hong Kong Profits Tax →

Related tools: IRD plea / mitigation letterCourt appearance / authorization letter

Draft templates only — not legal advice.

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