Mr Lam, the managing director of one of your clients, Galaxy Trading Limited, came to your office. He was concerned about restructuring his own salaries package, and that of the other employees. He wanted to ensure that all fringe benefits provided by the company were to be provided in a tax efficient manner i.e. to minimize the salaries tax liabilities of the employees but at minimal costs to the company.

Required:

(a) Explain to Mr Lam the extent to which fringe benefits are subject to salaries tax in Hong Kong with reference to the relevant statutory provisions and general principles.

(b) Advise him how to provide the following fringe benefits to the employees of the company in a tax efficient manner:

(i) a domestic helper

(ii) low interest loan

(iii) club membership

(iv) education fee of child