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Classifying the flow
Content date: 2026-08-24
Overall framework
Hong Kong has no exchange control and funds move freely; the binding constraints sit almost entirely on the Mainland side. Any plan starts by classifying the flow by nature (see table) and then mapping the Mainland filings to it — Hong Kong’s freedom does not answer for Mainland compliance.
Classifying the flow and the filings on each side
| Flow | Nature | Core Mainland filings |
|---|---|---|
| Mainland → Hong Kong injection | ODI | NDRC + commerce + FX registration |
| Mainland → Hong Kong service fees | Trade in services | Tax filing above US$50,000 + withholding (10%; 7% under the Arrangement) |
| Hong Kong → Mainland dividends | Profit repatriation | 10% withholding (5% under the Arrangement, three tests) |
| Mainland individual funds | Personal | US$50,000 annual convenience quota |
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.