A sustainable tax practice involves being aware of a company’s tax “footprint” and whether it aligns with the policy intent, having the right risk control and management processes in place, and accepting accountability for the consequences of a company’s actions.
With an advance ruling, you can confidently plan their transactions with the assurance that the tax treatment has been agreed in advance and to avoid tax disputes.
Does the new FSIE regime impact your company’s tax liability on passive income? Should you take any actions, such as strengthening your economic substance in Hong Kong? Will it help to modify your current business and investment structure?
It is sometimes argued that a company incorporated under HK Law (“HK Co”) will (a) automatically be regarded as a Hong Kong tax resident; and (b) only be subject to corporate tax in Hong Kong but not in other tax jurisdictions. However, one has to be well aware that if HK Co lacks (has insufficient) ‘tax […]