Hong Kong Legal Articles & Insights

Recent developments show that Chinese tax authorities are taking a stricter approach when reviewing dividend payments flowing from mainland China to Hong Kong holding companies (“Hong Kong HoldCo”). While the China–Hong Kong tax arrangement continues to offer a reduced 5 percent withholding tax rate on dividends, access to this benefit is no longer straightforward.

When an employment relationship comes to an end, it is common for employers to offer a termination package to employees. Some of these payments are taxable as Salaries Tax under Hong Kong laws, but some heads of payment may be treated as non-taxable if structured carefully. This article is a practical guide on simple steps that may be taken by both the employers and the employees to structure termination payment in a legal and compliant, yet tax-efficient manner.

This article talks about a development in international taxation in progress for a while now: BEPS 2.0, addressing tax avoidance by MNEs

Author: Chloe Lau , Associate Solicitor Understanding the Hong Kong Certificate of Resident Status The IRD issues a CoR to prove resident status for tax benefits under the DTA. From June 12, 2023, the IRD will use the DTA definition of “resident of Hong Kong”. The application process for Mainland China tax benefits is also simplified. However, a CoR doesn’t guarantee successful claims and entities may need to show economic substance in Hong Kong. What Is a Hong Kong Certifica

Author: Samantha Bradley, Consultant A New Tax Concession for Hong Kong Single Family Offices The Hong Kong government has set out its ambition to host 200 family offices in Hong Kong by 2025. The government perceives this sector to be of broad benefit to Hong Kong due to the multiplier effect on professional services, capital markets, venture capital and private philanthropy. On 24 March 2023, the government issued a policy statement on the development of family office busin

Author: Janine Sauerborn Understanding Hong Kong Double Taxation Agreements Everybody who deals with the topic of taxes will come into contact with a double taxation agreement , or DTA , at some point and will realise that it is not as bad as it sounds. This article provides an overview of Hong Kong double taxation agreements , explains why they exist, and how they operate in practice. The Basic Problem That Double Taxation Agreements Address In order to understand what a Dou

Jeder, der sich mit dem Thema Steuern befasst, wird irgendwann mit einem Doppelbesteuerungsabkommen (DBA) in Kontakt kommen und...

Für alle, die Hong Kongs Steuersystem in den letzten Jahren oder Jahrzehnten insbesondere im Hinblick auf die Besteuerung von...

Thanks to the relatively low tax rate, Hong Kong has long been one of the renowned locations for business registration. Specifically, the adoption of the territorial principle which could lead to offshore taxation allowed tax exemption for foreign-sourced profits, leading to situations where profits generated by a Hong Kong entity were not taxable in Hong Kong and were also not taxable in other jurisdictions.