One can potentially enjoy a significant withholding tax saving on the distribution/payment of dividends, interests or royalties from out of Mainland China by applying the Mainland China DTAs, subject to certain conditions.
One can potentially enjoy a significant withholding tax saving on the distribution/payment of dividends, interests or royalties from out of Mainland China by applying the Mainland China DTAs, subject to certain conditions.
The Comprehensive Avoidance of Double Taxation Arrangement between Hong Kong and Macao (“CDTA-HK/MC”) is the latest of Hong Kong 45 international double taxation agreements. It has entered into force on 18 August 2020. It will be applied in Macao and Hong Kong as from 1 January 2021 and 1 April 2021 respectively. This agreements follows… Continue reading Double Taxation between Macao and Hong Kong Arrangement In Force
On 19 August 2020, the government of the United States (“the US”) announced that the agreement in respect of double taxation relief on income derived from the international operation of ships entered into between the US and Hong Kong (“the Agreement”) has been terminated which will revert Hong Kong to the general shipping income tax… Continue reading Termination of the Shipping Income Tax Agreement Between the United States and Hong Kong
For many multinational companies, Hong Kong remains the preferred bridge between Asia-Pacific opportunity and Western capital. Competitive base salaries help attract talent, yet it is the carefully structured fringe benefits package that often seals the deal. Under Hong Kong’s Salaries Tax regime, however, every non-cash perk must be weighed against the Inland Revenue Department’s rules—principally… Continue reading Fringe Benefits and Tax Efficiency in Hong Kong for International Employers
Whether you’re an individual investor or running a company with investment activities, understanding how investment income is taxed (or not taxed) in Hong Kong can make a real difference to your bottom line.
Pursuant to the Enterprise Income Tax (‘EIT’) Law in Mainland China, capital gains derived by non-resident enterprises from the transfer of directly held equity interest in (i) Chinese resident entities or (ii) movable/immovable properties in Mainland China (collectively referred as the ‘Interest in Mainland China’) are generally subject to capital gain tax in Mainland China.… Continue reading Indirect Transfer of Properties in Mainland China by Non-resident Enterprises
As an international trading and financial centre, Hong Kong double taxation agreements (‘DTAs’) with its trading partners are essential to provide investors certainty in respect of taxing rights and incentives for carrying on business in Hong Kong. The DTA network also stimulates the development of a mutual economy, prevents discrimination and double taxation. Apart from… Continue reading Hong Kong Double Taxation Agreements and Tax Information Exchange Agreements
The Organisation for Economic Co-operation and Development (“OECD”) has developed a raft of action plans in order to counter Base Erosion and Profit Shifting (“BEPS”). According to OECD, BEPS refers to tax planning strategies that exploit gaps and mismatches in tax rules to make profits “disappear” for tax purposes or to shift profits to locations… Continue reading BEPS & Automatic Tax Exchange of Information
In order to improve the implementation of double tax treaties between Mainland China and other tax jurisdictions, the State Administration of Taxation of Mainland China (“SAT”) released in February 2018 a Public Notice [2018] No. 9 (“Public Notice 9”), providing further and clearer guidelines/rules in assessing the Mainland China beneficial ownership (“BO”) status for the… Continue reading Mainland China Beneficial Ownership
Pursuant to a co-operation framework agreement entered into in July 2017, Hong Kong, Macau and nine municipalities in the Guangdong Province of Mainland China including Guangzhou, Shenzhen, Zhuhai, Foshan, Huizhou, Dongguan, Zhongshan, Jiangmen and Zhaoqing have strategically integrated to form the Greater Bay Area (“GBA”), with a view to develop the region as a world-class… Continue reading Tax Incentives in the Greater Bay Area and Free Trade Zones/Port in Southern China
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