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Order of work
Content date: 2026-08-24
Order of work
Establish residence and the substance behind beneficial ownership first (people, decisions and expenditure matching the income), then obtain the certificate and the holding evidence, and file with the competent Mainland authority. Where the chart and the real seat of decisions diverge, treaty treatment is the first thing to be challenged.
Case-specific decisions differ — book a consultation with our advisers.
The content of this page is general professional information and does not constitute tax, legal or investment advice. For specific cases, please consult a Hong Kong practising accountant or tax adviser, or refer to official publications of the IRD / SFC / HKMA / CR.