It also implies that a statement of loss, which grants no objection option to the taxpayer, has a different status with the notice of assessment. An assessment cannot be re-opened after being final and conclusive after 6 years (or 10 years in the case of willful tax evasion). On the contrary, a case of tax loss, even agreed by the CIR in previous year, can be re-opened at any time in the future since it is technically not an assessment. See also Inland Revenue Department (Hong Kong) Section 5 of the IRO - Property tax Section 8 of the IRO - Salaries tax Reference links Section 14 of the IRO HK Inland Revenue Department: Questions and Answers A Guide by Law&Trust about corporate (profit) taxation in Hong Kong Different profit tax standard rates apply to corporation and unincorporated business References Taxation in Hong Kong