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

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Profits Tax - Notional expenditure

Notional expenditure means the expenditure only exists imaginarily and no money has been paid for such "expenditure".

Usually, it is the loss anticipated or profit forfeited if an act or transaction were done. In economics, it is called "opportunity cost".

By the "prudence concept" or "historical cost concept" of the generally accepted accounting principles, such expenditure cannot be a deductible expense in the accounts.

Because generally accepted accounting principles are followed for tax purpose, save specific provisions in the tax law, notional expenditure is not deductible. 

In the case Lowry versus Consolidated African Selection Trust Ltd. 23 TC 259, the company claimed a deduction that involved no expenditure --- the company issued shares to its employees at par value which was considerably below the then open market value --- the taxpayer claimed the difference as an expenditure. The court rejected the claim.

Tax guide on excessive remuneration


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