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稅務局
香港特別行政區

Dear Mr. LEE,

Code on Access to Information
Re: Application No. 340/2026

        We refer to your application dated 12 March 2026, seeking access
to the information regarding the Profits Tax returns received and
assessments issued for each sub-type or category of the “Persons Other
Than Corporations” for the past 10 years of assessment from 2017 to 2026.

        After careful consideration of your request, we regret that we are
unable to provide the information requested for the reason set out in
paragraph 1.1.4 in Part 1 of the Code on Access to Information (“the
Code”), which states –

1.14  The Code does not oblige department to -

• acquire information not in their possession
• create a record which does not exist
….

Since the Department does not maintain the statistics on the Profits Tax
returns received and assessments issued in terms of different sub-types or
categories of the “Persons Other Than Corporations”, it is regretted that
your request cannot be acceded to.

As an alternative, we would like to provide the following relevant
information for your perusal:
(a)        Total number of Profits Tax returns received from “Persons
Other Than Corporations” (excluding sole proprietorships) in each
financial year from 2016/17 to 2025/26.

Financial year No. of returns received
2016/17 20,565
2017/18 19,856
2018/19 19,623
2019/20 19,010
2020/21 17,335
2021/22 17,131
2022/23 16,851
2023/24 15,624
2024/25 16,272
2025/26 15,403
(up to 28 February 2026)

(b)        Total number of Profits Tax assessments issued to “Persons
Other Than Corporations” (excluding sole proprietorships) in each
financial year from 2016/17 to 2025/26 (for the years of assessment from
2015/16 to 2024/25).

Financial Year Year of assessment No. of assessments issued
2016/17 2015/16 15,774
2017/18 2016/17 15,104
2018/19 2017/18 14,487
2019/20 2018/19 11,917
2020/21 2019/20 11,884
2021/22 2020/21 11,571
2022/23 2021/22 11,353
2023/24 2022/23 10,745
2024/25 2023/24 10,897
2025/26 2024/25 10,321
(up to 28 February 2026)

        If you are not satisfied with the above decision, you may ask the
Department to review the decision by writing to the Commissioner of Inland
Revenue. Alternatively, you may complain to the Ombudsman, whose address
is –

        30/F., China Merchants Tower
        Shun Tak Centre
        168-200 Connaught Road Central
        Hong Kong

        Telephone:  2629 0555
        Fax:            2882 8149        

Regards,
Miss LAU Kin, Rosina
Chief Assessor (Special Duties)

From:        "Sebastian Lee"
<[FOI #1567 email]>
To:        "FOI requests at Inland Revenue Department"
<[Inland Revenue Department request email]>
Date:        2026/03/12 上午 10:43
Subject:        Freedom of Information request - Statistics on the types
of "Persons Other Than Corporations" and relevant statistics
Sent by:        [FOI #1567 email]

══════════════════════════════════════════════════════════════════════════

Dear Inland Revenue Department,

Subject: Request for Information under the Code on Access to Information –
Types of "Persons Other Than Corporations" and statistics

I am writing to request information under the Code on Access to
Information regarding the types of unincorporated entities within the tax
system.

For the purposes of tax administration, the Inland Revenue Department
issues specific tax returns for different legal entities, including the
"Profits Tax Return - Persons Other Than Corporations". As unincorporated
bodies of persons, organizations such as clubs, societies, and
associations fall under this category. Furthermore, I understand the
Department may also issue provisional or final tax assessments (including
estimated assessments under Section 59(3) of the Inland Revenue Ordinance)
to entities.

I kindly request the following information:

1) A list of the sub-types or categories of entities that have submitted
the "Profits Tax Return - Persons Other Than Corporations" over the past
10 years of assessment, between 2017-2026.
2) A similar list of sub-types or categories of entities within this
category of “Persons Other Than Corporations” that were issued a
provisional or final tax assessment by the Department over the same
period.

Specifically, I would like to know the aggregate:

a) number of returns submitted by each type of entities.
b) The number of provisional/final assessments issued to each type of
entities.

Thank you for your time and assistance in processing this request. I look
forward to your reply within the statutory timeframe.

Yours faithfully,
Sebastian Lee

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