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| Additional information |
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| Amicorp Hong Kong Ltd. |
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Profile:
Amicorp Hong Kong provides all Amicorp Group products and services. Some principal structures employed through Hong Kong include: Trading Companies. Hong Kong companies are ideal entities for international cross-border trading. Hong Kong trade companies usually avoid local corporate income taxation due to the territorial tax assessment system. A multitude of various transactions are available including import and exportation of goods and the re-invoicing of goods and services. This is usually the purchasing of goods from China/Asian countries and their resale through the Hong Kong Company. As the sales of the Hong Kong Company are made outside the Hong Kong territory there is no income tax on the profits. The structure can also be employed for the provision of consulting services. Where used for the purchase of products in China, profits received can be managed to remain outside China for future investment uses within a trading group. In this structure, the Hong Kong trade company is seen as a separate entity due to the 'one country, two systems principle' of the region. Beyond mere re-invoicing, the Hong Kong Company can so contribute value to the resale process (e.g., product development, quality control and logistical services). The Hong Kong / Belgium Route. Hong Kong's first Double Income Tax agreement was with Belgium. The benefits of a tax treaty provide that withholding tax on Belgian distributions made to Hong Kong can be eliminated provided, the Hong Kong company holds a substantial interest in the share capital of the Belgian company. The reductions through Belgium are quite advantageous considering the freedom to utilize the European Union's Parent/Subsidiary Directive. This Directive eliminates withholding taxes on intra-European Union distributions of interest, royalties and dividends from Belgium. This link creates an attractive exit route from Europe. |
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Overview:
With a low tax regime and simple territorial taxation system, Hong Kong is an excellent location for structuring holding, financing, intellectual property and trading structures. Hong Kong is also an ideal gateway for setting up of Chinese inbound and outbound investments structures. Furthermore, Hong Kong is the only Renmibi clearing center outside the People’s Republic of China (PRC) with a regulated stock market.
The main advantages of Hong Kong include:
No taxation on the receipt of dividends;
Territorial taxation system (only income derived from Hong Kong is subject to Hong Kong tax);
No withholding taxes on dividends and interest;
No withholding taxes on royalties unless place of acquisition and place of granting of license or right of use is Hong Kong;
No tax on capital gain;
No interest tax;
No currency exchange controls or restrictions;
No VAT or GST;
Advanced tax rulings are available from the Hong Kong Inland Revenue Department;
Not on the blacklists of many major commercial countries;
No minimum holding requirement;
No thin capitalization rule;
No controlled foreign corporation provisions;
Currency pegged to the US dollar;
Double tax agreements with 24 countries;
Closer Economic Partnership Arrangement with the PRC.
Hong Kong is expanding its tax treaty network. As of May 2012, Hong Kong has signed comprehensive double taxation agreements with 25 countries, including Belgium, Thailand, the People's Republic of China, Luxembourg, Vietnam, Brunei, the Netherlands, Indonesia, Hungary, Kuwait, Austria, the United Kingdom, Ireland, Liechtenstein, France, Japan, New Zealand, Switzerland, Portugal, Spain, Czech Republic, Malta, Jersey, Malaysia and Mexico.
For more information about structuring through Hong Kong and services offered by Amicorp Hong Kong, please see the specialized Amicorp brochure.
Languages spoken: Cantonese, English and Putonghua |
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