National toll free hotline:
400-711-2005
注册香港公司(英文)
Hong Kong adopts a territorial source principle of taxation. Only profits which have a source in Hong Kong are taxable here. Profits sourced elsewhere are not subject to Hong Kong Profits Tax. The principle itself is very clear but its application in particular cases can be, sometimes, contentious.
To clarify the operation of the principle, Inland Revenue Department prepared a [ simple guide on the territorial source principle of taxation ].
It gives a brief explanation of how the principle operates and provides simple examples for illustrative purposes of the tests applied to different types of businesses. If you wish to explore the subject in greater depth, consultation with professional advisers is recommended.
Setup a Hong Kong company is simple.
Join our services can fulfill all Hong Kong government requirements.
Hong Kong Company | Singapore Company | BVI Company | |
Number of shareholder | At least 1 | At least 1 | At least 1 |
Number director | At least 1 | At least 1 | At least 1 |
Director nationality | No restriction | 1 of directors should be Singapore resident | No restriction |
Shareholder also can be Director | Yes | Yes | Yes |
Commonly used as
· Holding company of a corporate structure;
· Vehicle for holding asset and trust;
· A tool to achieve risk management and tax planning for international business.
Background
1. France company (F Ltd) 100% own a subsidiary WFOE (C Ltd) in China;
2. C Ltd provide consulting service to China based business;
3. Dividend by C Ltd to mother company F Ltd is taxable in China;
4. The withholding tax rate is 10% for a France company.
New arrangement
1. France company (F Ltd) setup a Hong Kong (H Ltd);
2. H Ltd 100% own a subsidiary WFOE (C Ltd) in China;
3. C Ltd provide consulting service to China based business;
4. Dividend by C Ltd to Hong Kong mother company H Ltd is taxable in China;
5. The withholding tax rate is 5% for a Hong Kong company.
6. Dividend income is non-taxable in Hong Kong.
Remark
· This withholding tax rate in China is varies and depends on country or region.
· Egypt company is 8%;
· US company, Japan company is 10%;
· Hong Kong company is 5%.
Background
1. France company (F Ltd) provides intellectual technology to a China company (C Ltd);
2. C Ltd should pay royalty fee RMB 1,000,000 to F Ltd;
3. This royalty fee is taxable in China;
4. The withholding tax rate is 10% for a France company;
5. When C Ltd remit the royalty fee to F Ltd, C Ltd should withheld 10% of total amount and pay to China tax bureau;
6. Finally, F Ltd only receive RMB 900,000.
New arrangement
1. France company (F Ltd) setup a Hong Kong (H Ltd);
2. Intellectual technology provide by H Ltd;
3. C Ltd should pay royalty fee RMB 1,000,000 to H Ltd;
4. This royalty fee is taxable in China;
5. The withholding tax rate is 7% for a Hong Kong company;
6. When C Ltd remit the royalty fee to H Ltd, C Ltd should withheld 7% of total amount and pay to China tax bureau;
7. H Ltd can receive RMB 930,000.
Remark
· Withholding tax rate is 10%;
· Under CEPA, Hong Kong can enjoy a special withholding tax rate of 7%.
24 hour hotline:+86 13588024949 BSI HOT-LINE:400-711-2005
Rm.220,Building3,Yuejuncheng,No.128,Hexing Road,Hangzhou City,Zhejiang,China. TEL:0571-85081281 85081282 85085700 FAX:0571-85081280
To visit in Shanghai:Shanghai xuhui district no. 2020 (HuaYi edifice) 2, 16 floor BSI HOT-LINE:400-711-2005
shenzhen:shenzhen futian district 2012 color entrance garden building A 21st floor BSI HOT-LINE:400-711-2005
Beijing:Beijing chaoyang district no. 88 jianguo SOHO modern city 5, 29 floor BSI HOT-LINE:400-711-2005
Hong Kong:Hong Kong - 55 constant ze commercial building 15 floor TEL:00852-31781676 FAX:00852-31781675
youchuang business consultant co., LTD Copyright© 2005-2015 HKCRS.com All Rights Reserved. 浙ICP备11008125