Knowledge centre
Explore practical guides, common questions and compliance dates. General information helps frame the questions; individual arrangements depend on the facts.
Formation and governance
Incorporating in Hong Kong: statutory requirements and annual dates
Incorporation is the easy part. The work is getting directors, secretary, registers and annual deadlines right from day one, so banking and tax start from a clean base.
Hong Kong vs Singapore: Choosing Your Asia Regional HQ
Compare customer markets, business substance, tax, banking and ongoing compliance costs together. Tax residence is one factor; headline rates alone cannot determine the choice.
Banking and business evidence
Accounting, audit and tax
Books, audit and annual compliance duties
Simplified reporting does not waive the audit requirement. The statutory exception for dormant companies must be assessed separately.
Hong Kong offshore profits: the source test
IRO s.14 charges profits arising in or derived from Hong Kong. Source follows the operations that produced the profit. DIPN 21 sets out how the IRD looks at those operations, including after the assessment.
Cross-border operations: source and transfer pricing
Hong Kong profits tax follows the source of profits. Intra-group goods, services and royalties follow the arm’s-length principle. Whether a Master File and Local File must be prepared depends on size and related-party volumes.
Cross-border structures and reporting
Mainland ODI into Hong Kong: filings and order of steps
Mainland outbound investment is handled separately by the development-and-reform authority, the commerce authority and SAFE. A Hong Kong company can be prepared in advance; equity and funds should follow once the Mainland papers can support them.
FSIE: foreign-sourced passive income received in Hong Kong
The FSIE regime has applied since 1 January 2023 to specified foreign-sourced passive income received in Hong Kong. Exemption depends on economic substance, the participation exemption or the nexus test.
What CRS sends to the other tax authority
CRS is automatic exchange of account information among participating jurisdictions. Hong Kong institutions report specified account-holder data to the IRD, which transmits it to the partner authority under IRO Schedule 17D. What moves is data, not an assessment — chargeability is decided by each jurisdiction under its own tax law.
Active and Passive NFEs under CRS
A non-financial entity (NFE) is classed under CRS due diligence as Active or Passive. The class decides whether the institution looks through the entity: Passive NFEs require identification of controlling persons, who are separately reported where they are resident in a reportable jurisdiction. The tests turn on income and asset composition, based on the self-certification and financial information.
Hong Kong accounts of Mainland tax residents: filing and credit
CRS delivering Hong Kong account data to the Mainland is not the completion of an individual income-tax filing. The filing and credit rules for Mainland tax residents’ overseas income rest on Public Notice 2020 No. 3 and the rules in force — the institution reports; the individual files; one does not discharge the other.
Three frequent CRS misunderstandings
CRS hands account data to the other tax authority; whether tax is charged, and how much, follows that authority’s own law. These three misunderstandings come up most in enquiries, and each is enough to send the response in the wrong direction.
Hong Kong single family offices and the profits-tax concession
A company set up to hold and administer one family’s own capital can be assessed against the qualifying family-office profits-tax concession. The concession has substance tests on assets, people and expenditure. Incorporation does not create the exemption.
Hong Kong trusts: the usual legal forms
Hong Kong trusts are governed mainly by the Trustee Ordinance (Cap 29). What follows is the usual architecture; trustee powers and beneficiaries are drafted on the facts.
BVI and Cayman holding companies and economic substance
BVI and Cayman companies are still used as holding or financing intermediates. They must meet local economic-substance rules and CRS reporting of controlling persons. Registration is not the same as substance.
Cross-border funds: ODI, current account and dividend withholding
Hong Kong has no general exchange control. Funds that originate in, or must return to, the Mainland still follow NDRC, commerce and SAFE rules.
Mainland–Hong Kong tax arrangement: applying the reduced rates
A qualifying Hong Kong resident company may claim reduced Mainland withholding on dividends, interest and royalties. The Arrangement is not automatic: a certificate of resident status, beneficial-owner status and the holding-period tests must all be met.
Annual obligations and common questions
Compliance calendar
This calendar is a reminder of general statutory milestones and does not constitute tax or legal advice. Specific obligations follow official publications of the IRD / CR / MPFA. Rates, allowances and payment dates change with each Budget.
FAQ
Practical reading on incorporation, accounting, audit and banking.