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Queenie, a resident in Thailand, has recently been offered a new job to work in Hong Kong for X Ltd, under a two-year employment contract.

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Queenie, a resident in Thailand, has recently been offered a new job to work in Hong Kong for X Ltd, under a two-year employment contract. X Ltd carries on business in Hong Kong and has its central management and control exercised in Hong Kong. X Ltd is a subsidiary of Y Ltd which carries on business in Thailand. Both X Ltd and Y Ltd are listed on the Singapore Stock Exchange. During a meeting with the human resource manager of X Ltd, Queenie discussed her remuneration package, in particular accommodation arrangement in Hong Kong: Accommodation arrangement in Hong Kong - X Ltd maintains a few apartments in Hong Kong for use as quarters by its regional staff. As Queenie is single, she will be entitled to live in a one-room flat, but will be required to pay a nominal rent of 3% of her monthly salary. Queenie is also responsible for paying the property management fee during the months of her stay. Alternatively, X Ltd may pay Queenie a fixed sum housing subsidy of up to $30,000 per month. Queenie has full discretion on how to use the subsidy without any restriction. Required: In respect of the proposed accommodation arrangement provided by X Ltd to Queenie, explain the following issues: (a) Whether Queenie's Hong Kong salaries tax position would be different if Queenie enters into the employment contract with Y Ltd as opposed to X Ltd. (2 marks) (6) How Queenie will be assessed to Hong Kong salaries tax if she lives in the staff quarters. (4 marks) (e) Whether, and if so how, Queenie's Hong Kong salaries tax position would be different if she chooses to receive the housing subsidy of $30,000 per month. (2 marks) (d) Assuming that Amy intends to lease an apartment or a hotel room, suggest at least one tax efficient planning scheme for Queenie, and how, such that her salaries tax liability could be minimised without any extra cost being incurred by X Ltd. (7 marks)

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