HK · CROSSBORDER · 06 · Hong Kong

Cross-border — Mainland, Greater Bay Area & Overseas

Hong Kong is a free port with a USD-pegged currency and close ties to the Mainland through CEPA — a natural gateway to China and Asia. Cross-border business brings opportunity, and with it multi-currency books, several tax systems and a lot of paperwork.

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Trade with the Mainland & the Greater Bay Area

Trade with the Mainland and Greater Bay Area from Hong Kong: CEPA origin rules, RMB invoicing, fapiao, permanent establishment risk and dispute enforcement.

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Import, Export & Declarations

Hong Kong is a free port, yet imports and exports must be declared within 14 days. See dutiable goods, licences, certificates of origin and the paper trail.

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Offshore Profits & the Territorial Principle

How an offshore profits claim works in Hong Kong: the source test, the evidence the IRD asks for, the 2023 FSIE rules and the mistakes to avoid.

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Regional Headquarters & Intra-group Charges

Running a regional headquarters from Hong Kong: management fees, cost recharges, arm's length pricing, royalty tax and the documents the IRD expects.

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Posting Staff to the Mainland & Overseas

Posting Hong Kong employees to the Mainland or overseas: salaries tax residence, the 60-day rule, IR56G notices, MPF questions and day-count records.

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Comprehensive Double Taxation Agreements

Hong Kong's comprehensive double taxation agreements: reduced withholding on dividends, interest and royalties, residence certificates and anti-abuse tests.

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