Hong Kong Advance Ruling on Whether a Company is a Qualifying Ship Lessor Eligible for a Concessionary Tax Rate

The Hong Kong Inland Revenue Department has published an advance ruling originally issued on 12 November 2025 on whether a Hong Kong–incorporated ship leasing company qualifies as a "qualifying ship lessor" under section 14P of the Inland Revenue Ordinance (IRO), which provides a concessionary tax rate for qualifying ship leasing activities.

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Advance Ruling Case No. 78

1. The provision of the Ordinance

The ruling applies in respect of section 14P of the Inland Revenue Ordinance ("IR…