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The Asia-Pacific Journal of Taxation (APJT)

Publishes research papers, commentary notes, book reviews and article abstracts that address significant issues in the field of taxation of relevance to Hong Kong, China and the Asian Pacific region. 

It is a biannual Journal for professionals and academics seeking to further their understanding of the tax field from the critical, analytical and developmental perspectives.


Jody Wong

The Hong Kong Polytechnic University

Percy Wong

The Hong Kong Polytechnic University

Philip Hung

The Taxation Institute of Hong Kong

Joseph Yau

The Taxation Institute of Hong Kong

Karmen Yeung

The Taxation Institute of Hong Kong



Agnes Cheng

The Hong Kong Polytechnic University

Nigel Eastaway


Andrew Halkyard


Michael Olesnicky


Charles Swenson

University of Southern California

Daniel Thornton

Queen’s University

Jefferson VanderWolk

Washington Council Ernst & Young



Samuel Chan

Hong Kong Community College

Daniel Cheung

The Hong Kong Polytechnic University



Brian Andrew

University of Wollongong

Jennifer Chang

PricewaterhouseCoopers, Malaysia

Cheng Chi


Spencer Chong

PricewaterhouseCoopers, HK

Wilson Chow

The University of Hong Kong

Gao Peiyong


Institute of Finance & Trade Economics Chinese Academy of Social Science

Daniel Ho

Hong Kong Baptist University

Patrick Ho

FTMS Training Systems (HK) Ltd

Simon James

University of Exeter

Zhao-dong Jiang

The Chinese University of Hong Kong

Jeyapalan Kasipillai

Monash University Malaysia

Larry A Kreiser

Cleveland State University

Patrick Kwong

Ernst & Young Tax Services Ltd

Yvonne Law

Deloitte Touche Tohmatsu, HK

Stephen Lee

Sinotax Services Ltd

Thomas Lee

Thomas Lee & Partners

Aldous Mak

Hong Kong Institute of Vocational Education (Haking Wong)   

Poh Eng Hin

Nanyang Technological University

Richard Simmons

Lingnan University, HK

Anthony Tam


Fergus Wong

PricewaterhouseCoopers, HK

Marcellus Wong

PricewaterhouseCoopers, HK

Chris Xing

KPMG, China

Editorial Policy

The Asia-Pacific Journal of Taxation publishes research papers, commentary notes, book reviews and article abstracts that address significant issues in the field of taxation of relevance to Hong Kong, China and the Asia-Pacific region. Research papers should be analytical and may be empirically or theoretically based. Studies of comparative practices or international research reports in the field of taxation are encouraged.

Editorial Procedures

Authors should submit three copies of their manuscripts to the Editor-in-chief.

Work submitted for consideration must be previously unpublished, not under consideration for publication elsewhere and, if accepted, should not then be published elsewhere in the same form. The author(s) should explicitly state that these conditions have been met in a covering letter to the Editor-inchief. If previously published figures, tables, or parts of text are to be included, the copyright holder’s permission must have been obtained prior to submission.

Manuscripts submitted to the journal will be reviewed by the editors for general suitability for publication. Those considered appropriate will be sent to two reviewers for evaluation using a double blind review procedure. Based on the recommendations of the reviewers, the editors will then decide whether the particular article should be accepted as it is, revised or rejected. The process so described is a general one. The editors, however, may, in some circumstances, vary this process at their discretion.

Guidelines for Manuscripts

All manuscripts are to be typewritten double spaced on one side (international-size A4 preferred; North American 8” x 11” letter size also acceptable). Margins should be about 15 cm or 1 inch to facilitate editing and duplication.

Cover page — The cover page should include the title of the manuscript, the name, title, affiliation, address, phone and fax number of each author, and any acknowledgement of financial, technical and other assistance.

Abstract page — The abstract page should have the title of the manuscript and a 100–150 words abstract but should not identify the author(s).

Text — Begin the text on a new page with the title but without the name of the author(s). Headings should be bold-faced, entirely in upper case while subheadings within the main headings should be bold-faced, in upper and lower cases. Footnotes, if unavoidable, should be kept to a minimum. They should be numbered consecutively throughout the manuscript, typed with double-spacing and collected on a separate page with the heading “Endnotes”. The endnotes should follow the last page of the text. Reference citations within the text should consist of the cited author’s last name and the year of publication, enclosed in parentheses, for examples: (Alm 1991), or (Brent, Morse and Stice 1990). If the author’s name appears in the sentence, only the year of publication should be in parentheses, for example : as discussed by Brent, Morse and Stice (1990). References to multiple works should occur within one set of parentheses, separated by semi-colons, for example : (Alm 1991; Brent, Morse and Stice 1990; and Lewellen and Mauer 1988).

References — References should be listed on a separate, double spaced page. This listing should only contain those references cited in the text of the manuscript. References are listed in alphabetical order by the first author’s last name. Samples of entries are as follows:

Alm, James (1991), “A Perspective on the Experimental Analysis of Taxpayer Reporting”, The Accounting Review, July, pp. 577–593.

Brent, Averil, Morse, Dale and Stice, E.K. (1990), “Short Interest: Explanations and Tests”, Journal of Financial and Quantitative Analysis, June, pp. 273–289.

Halkyard, Andrew and Vanderwolk, J.P. (1993), Hong Kong Tax Law—Cases and Materials, Butterworths Asia.

Lewellen, W.G. and Mauer, D.C. (1988), “Tax Options and Corporate Capital Structures”, Journal of Financial and Quantitative Analysis, December, pp. 387–400.

Upon acceptance of a paper for publication, the author(s) will be requested to submit a carefully-edited version of the manuscript both hard copy and on diskette using a word processor that is compatible with MS-DOS. The author(s) will be required to sign a copyright release form as a condition of publication. Author(s) of accepted manuscripts will be provided with proof copies of their articles for proofreading. Neither the editors nor the journal will accept responsibility for errors, omissions, loss or damage to manuscripts.

Vol. 17 No. 1 — Spring/Summer 2013

HK Technical Column

27th Vol. of Decisions of the Board of Review (Inland Revenue)

Godwin Ng

Special Measures on Stamp Duty for Hong Kong Property Transactions

Davy Yun & Doris Chik

PRC Technical Column

Chinese Anti-tax Avoidance Measures in Action

Matthew Mui, Fergus Wong & Joyce Qian

Circular 165: China’s Most Recent Guidance Concerning the Meaning of “Beneficial Owner”.

Yi Ying Cheng, Yiu Hong Chung & Leonard Teik Gin Khaw

International Technical Column

Marketing Intangibles — An Increasing Area of Focus in Transfer Pricing

Shanto Ghosh, Neeta Punjabi & Rahul Tomar


Charting The Future: How is Hong Kong Responding to International Pressure for Enhanced Transparency, Cooperation, and Information Exchange on Taxation Matters?

Adrian Sawyer


Ms Scarlett Ho
Asia-Pacific Journal of Taxation
School of Accounting and Finance
Faculty of Business
The Hong Kong Polytechnic University
Hung Hom, Kowloon, Hong Kong.
Tel. (852) 2766 4538 Fax: (852) 2774 9364