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Current account: service fees

Current account: service fees

Outbound service-trade payments above the equivalent of US$50,000 require a tax filing. Payments from a Mainland enterprise to a Hong Kong company also attract non-resident enterprise income tax withholding: 10% in general, 7% or lower under the Arrangement for a qualifying Hong Kong company (certificate of resident status plus beneficial ownership). Where the services are performed in turn decides the Hong Kong side of the analysis (DIPN 21: service fees follow the place of performance).

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