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INCOME TAXES
6 Months Ended
Jan. 31, 2024
Income Tax Disclosure [Abstract]  
INCOME TAXES

NOTE 5 – INCOME TAXES

 

Income Taxes

 

Seychelles

 

RQS United is incorporated in Seychelles and is not subject to tax on income generated outside of Seychelles under the current law. In addition, upon payment of dividends, no withholding tax is imposed under current law.

 

Hong Kong

 

Roshing is incorporated in Hong Kong and is subject to Hong Kong Profits Tax on the taxable income as reported in its statutory financial statements adjusted in accordance with relevant Hong Kong tax laws. The applicable tax rate is 8.25% in Hong Kong. Hong Kong income tax expenses (benefit) for the six months ended January 31, 2024 and 2023 amounted to $11,972 and $0, respectively.

 

For the six months ended January 31, 2024, the income before provision for income taxes of $106,574, consisted of United States source loss of $(197,930) and Hong Kong source income of $304,504. For the six months ended January 31, 2023, the loss before benefit from income taxes of $(6,629) was all Hong Kong source loss.

 

Significant components of the provision for income taxes are as follows:

        
   For the six months ended 
  

January 31,

2024

  

January 31,

2023

 
   (Unaudited)   (Unaudited) 
Current Hong Kong  $11,972   $ 
Deferred Hong Kong        
Provision (benefit) for income taxes  $11,972   $ 

 

The following table reconciles the Hong Kong statutory rates to the Company’s Hong Kong effective tax rate:

        
  

For the six months ended
January 31,

2024

  

For the six months ended
January 31,

2023

 
    (Unaudited)    (Unaudited) 
Hong Kong statutory income tax rate   8.25%    8.25% 
Prior year overaccrual of provision for income taxes   (4.32)%     
Change in deferred tax asset valuation allowance        (8.25)% 
Effective tax rate   3.93%    % 

 

For United States income tax purposes, Tianci has a net operating loss carry forward of approximately $1,165,337 at January 31, 2024. Management has not determined that it is more likely than not that this carryforward will be realized and thus the Company maintained a 100% valuation allowance for the deferred tax asset relating to the United States net operating loss carryforward. Current United States income tax law limits the amount of loss available to offset against future taxable income when a substantial change in ownership occurs.

 

Uncertain tax positions

 

The Company evaluates each uncertain tax position (including the potential application of interest and penalties) based on the technical merits, and measures the unrecognized benefits associated with the tax positions. As of January 31, 2024 and July 31, 2023, the Company did not have any significant unrecognized uncertain tax positions.

 

As of January 31, 2024, tax years 2021 and forward generally remain open for examination for United States Federal and State tax purposes and tax years 2017 and forward generally remain open for examination for foreign tax purposes.