Hong Kong Corporate Tax and Profits Tax Services
We help Hong Kong companies and cross-border groups handle profits tax returns, offshore profits claims, advance rulings, FSIE, related-party transactions and Inland Revenue Department enquiries. Each tax position is assessed against the actual business operations, contracts, people and transaction records.
Corporate Tax Support Beyond Routine Filing
Our work covers profits tax compliance and non-standard corporate tax matters where the source of profits, group arrangements or supporting evidence requires closer review. Outcomes depend on the facts, applicable law and the Inland Revenue Department's assessment.
Tax Compliance
Ensuring your business adheres to all tax regulations and filing requirements.
Cross-Border Tax Advisory
Professional guidance on international tax matters and overseas expansion strategies.
Complex Case Review
Review the facts, filing history, evidence requirements and potential exposure before preparing a profits tax return or IRD response.
An Offshore Company Is Not Automatically Tax-exempt
The place of incorporation, bank account or invoicing address does not by itself determine the source of profits. An offshore profits claim requires a fact-specific review of where and how the profit-producing activities took place, while specified foreign-sourced income may also fall within the FSIE regime.
Complex Corporate Tax Matters We Handle
We review the commercial facts and supporting records before recommending a filing position or response strategy.
Offshore Profits Claims
Trace the profit-producing activities and organise contracts, orders, personnel, logistics and correspondence for an offshore profits claim and related IRD enquiries.
Advance Rulings
Assess whether a proposed transaction may be suitable for an advance ruling and prepare a complete statement of facts and supporting documents.
Offshore and Non-Hong Kong Companies
Review whether an overseas-incorporated or offshore company carries on business in Hong Kong and how its Hong Kong tax obligations should be addressed.
Foreign-sourced Income Exemption (FSIE)
Review specified foreign-sourced interest, dividends, disposal gains and intellectual property income against the applicable FSIE conditions.
Cross-border Trading, E-commerce and Services
Map negotiations, contracting, fulfilment, service delivery and personnel locations to analyse the source of profits.
Related-party Transactions and Transfer Pricing
Review group service fees, loans, royalties, cost sharing and other controlled transactions for arm's-length and documentation requirements.
Group, Holding and Complex Structures
Examine ownership, control, management functions and connected entities, including eligibility for the two-tiered profits tax rates.
Restructuring, Share Disposals and Tax Losses
Consider the tax treatment and filing implications of reorganisations, business transfers, share disposals and carried-forward losses.
Assessments, Objections and Tax Investigations
Prepare responses to estimated or additional assessments, objection notices, information requests and tax investigation correspondence.
Our Corporate Tax Services
Corporate Tax Returns
Professional corporate tax filing services:
- Preparation and submission of profits tax returns
- Compliance with statutory filing deadlines
- Maximization of available tax deductions
Tax Compliance
Comprehensive tax compliance support:
- Tax risk assessment
- Compliance reviews and monitoring
- Statutory tax filing assistance
Corporate Tax Case Support
Fact-based support for complex filings:
- Profit-source and FSIE review
- Group transactions and supporting evidence
- Assessment objections and IRD enquiries
How We Handle a Corporate Tax Case
A structured review keeps the filing position consistent with the underlying business records and identifies evidence gaps early.
- 1
Initial Fact Review
Understand the entity, transaction, commercial objective, filing history and questions raised by the IRD.
- 2
Source and Risk Analysis
Map the people, functions, contracts and transaction flow against the relevant Hong Kong tax rules.
- 3
Filing and Evidence Package
Prepare the tax return position, computations, explanations and supporting document index for review.
- 4
IRD Correspondence and Follow-up
Coordinate responses, clarify further questions and track statutory filing, objection and payment deadlines.
Documents Commonly Required
- Profits tax returns, assessments and prior tax computations
- Financial statements and supporting accounting records
- Contracts, purchase orders, invoices and transaction schedules
- Negotiation records, emails and evidence of where activities occurred
- Staff, director, travel and management-function records
- Bank statements and payment or transaction-flow records
- Group charts, related-party agreements and transfer pricing documents
- IRD correspondence, prior claims and ruling documents
Corporate Tax Frequently Asked Questions
Practical answers to common Hong Kong profits tax and complex corporate tax questions.
Is an offshore company automatically exempt from Hong Kong profits tax?
No. Incorporation outside Hong Kong does not create an automatic exemption. The company must be reviewed against whether it carries on business in Hong Kong and where the relevant profit-producing activities took place.
What evidence is needed for an offshore profits claim?
The evidence depends on the business model, but commonly includes contracts, orders, negotiation records, staff and service locations, logistics records, emails and a complete transaction flow.
When may an advance ruling be appropriate?
It may be considered for a proposed arrangement with material tax uncertainty. The application requires full disclosure of the relevant facts and documents, is subject to a fee and remains for the IRD to determine.
How is FSIE different from an offshore profits claim?
FSIE may apply to specified foreign-sourced income received in Hong Kong by a multinational enterprise entity carrying on a trade, profession or business in Hong Kong. The income type, economic substance and available exception or relief must be reviewed separately from the general source-of-profits analysis.
Can every company in a group use the two-tiered profits tax rates?
Generally, only one entity among connected entities may be nominated for the two-tiered rates. Ownership and control relationships should be reviewed before making the election.
Official Resources
Check the latest Inland Revenue Department guidance relevant to this service before making filing, compliance or planning decisions.
Related Services
Clients often combine this service with the following support areas, depending on their reporting, tax, or growth requirements.
Accounting
Professional bookkeeping and financial statement preparation
Learn MoreTax Planning
Strategic tax planning and optimization
Learn MoreIndividual Tax
BIR60 and salaries tax filing support for cross-border income, aircrew, expatriates and IRD enquiries.
Learn MoreNeed Help with a Complex Corporate Tax Case?
Share the transaction background, tax notices and available records with us for an initial review of the filing position, evidence needs or IRD response.
Contact Us