Raymond Yeung Tax Consultant former Assessor of Inland Revenue Department 前稅局評稅主任楊輝洪

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Industrial Building Allowance - Initial allowance 

Section 34(1) of Inland Revenue Ordinance allows an initial allowance of 20% on the capital expenditure incurred in the basis period of the year of assessment.

Any expenditure incurred before trading is taken to be incurred on the first day of trading --- vide Section 40(2).

If the expenditure is paid by installments, it is necessary to determine the basis period in which each installment is legally due.

Building bought unused from a property developer or otherwise. 

Where the building is bought from a property developer, the purchaser can also claim initial allowances (in addition to annual allowance) if no initial allowance has been granted to the seller. The person who buys the interest is deemed to have incurred, on he date on which the purchase price is payable, capital expenditure on construction of an amount equal to the “price” paid by the purchaser. The “price” must exclude the part paid for the “land”.  

Where the building is not bought from a property developer, the purchaser can also claim initial allowances (in addition to annual allowance) if no allowances have been granted to the seller. The person who buys the interest is deemed to have incurred, on he date on which the purchase price is payable, capital expenditure on construction of an amount equal to the “price” paid by the purchaser or the actual cost of the construction if this  is lower. The “price” must exclude the part paid for the “land”.  

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