{
  "publisher": {
    "name": "Provedays",
    "url": "https://provedays.com"
  },
  "license": "CC BY 4.0",
  "license_url": "https://creativecommons.org/licenses/by/4.0/",
  "attribution": "Provedays — provedays.com",
  "notice": "Rule data is licensed CC BY 4.0. Golden test fixtures, guide prose and the rule schema are not covered by this licence and remain all rights reserved. See https://provedays.com/terms/.",
  "documentation": "https://provedays.com/methodology/",
  "rule_id": "hk.salaries.60day",
  "versions": [
    {
      "rule_id": "hk.salaries.60day",
      "version": "2026.1",
      "jurisdiction": "HK",
      "title": "Hong Kong 60-day visits rule (salaries tax) — ADVISORY",
      "summary": "IRO s.8(1B): for a non-Hong-Kong employment, services rendered in Hong Kong during VISITS totalling 60 days or fewer in the year of assessment (1 April – 31 March) are disregarded — exceeding 60 visit days makes Hong Kong service income taxable. This is an exemption condition on salaries tax, not a residence test: Hong Kong has no general day-count residence rule, and whether presence is a 'visit' and what income is attributable involve facts beyond day counting.",
      "evaluator": "fixed_window_threshold",
      "determinative": false,
      "official_source_url": "https://www.elegislation.gov.hk/hk/cap112!en/s8",
      "last_verified": "2026-09-01",
      "effective_from": "2000-01-01",
      "effective_to": null,
      "disclaimer_level": "advisory",
      "convention": {
        "unspecified_by_authority": true
      },
      "params": {
        "reference_period": {
          "type": "tax_year",
          "start_month": 4,
          "start_day": 1
        },
        "threshold": 60,
        "op": "<=",
        "direction": "avoid",
        "countries": [
          "HK"
        ]
      },
      "notifications": [
        {
          "at_count": 50,
          "at_fraction_of_limit": null,
          "message_key": "hk60.approaching"
        }
      ],
      "notes": [
        "Read at e-Legislation (cap. 112 s.8) on 1 September 2026. s.8(1B): 'no account shall be taken of services rendered in Hong Kong during visits not exceeding a total of 60 days in the basis period for the year of assessment.'",
        "The exemption attaches to s.8(1A)(b): income from services rendered ENTIRELY outside Hong Kong is excluded (not for government employment or ship/aircraft crew); s.8(1B) tolerates up to 60 days of visit-services inside that.",
        "Crew rule, s.8(2)(j): ship masters/crew and aircraft commanders/crew are excluded when present ≤60 days in the year of assessment AND ≤120 days across two consecutive years of assessment — a two-year pairing not yet modelled.",
        "The DTA 180/300-day test (Comprehensive Arrangement art. 4(1)(2)) is TREATY residence, not salaries tax, and is treaty-specific — do not generalise.",
        "Hong Kong publishes no counting basis for a 'day' or a 'visit' across these tests (convention.unspecified_by_authority); the IRD applies days-of-presence practice that this counter approximates with any-part-of-day."
      ]
    }
  ]
}