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Tax Advisory

CW CPA provides tax advisory services in Hong Kong and Mainland China to support businesses navigating complex tax regulations, compliance obligations and cross-border tax considerations. Hong Kong and Mainland China each have distinct tax regimes, and effective tax planning and compliance support help businesses manage risk and optimise their tax positions. Our tax advisors work with clients of various sizes and structures to deliver practical, compliance-oriented tax guidance tailored to local requirements.

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Our Working Approach
  • A risk-based focus on material tax exposures and compliance priorities, rather than theoretical analysis
  • Consideration of tax implications at both company and group level, particularly for holding and cross-border structures
  • Coordination with tax advisory teams within the Allinial Global network to support international and multi-jurisdictional tax matters
  • Clear communication of tax implications to support management decision-making and compliance planning

Our Tax Advisory Services

Tax Advisory services provide technical interpretation, structuring advisory, compliance support, and dispute management across domestic and cross-border tax regimes. These services include corporate tax advisory, international tax structuring, global minimum tax advisory, transaction tax advisory, indirect tax advisory, tax risk management, and individual employment tax planning. The objective is to optimise tax positions, manage regulatory exposure, and align tax strategy with commercial objectives.

Hong Kong Profits Tax Advisory

  • Advisory on the application and interpretation of the Inland Revenue Ordinance in relation to business operations.
  • Analysis of deductibility of expenses, revenue characterisation, and source of profits issues.
  • Advisory on tax implications of new business models, contractual arrangements, and cross-border service structures.
  • Assessment of permanent establishment exposure and Hong Kong taxable presence risks.
  • Support tax-efficient structuring of Hong Kong business operations.

Territorial Source & Offshore Profits Advisory

  • Advise on the application of the Hong Kong territorial source principle in determining the source of profits.
  • Assess whether trading, service, or commission income is regarded as arising in or derived from Hong Kong.
  • Analyse operational structure, contract execution, and decision-making processes to evaluate offshore claim eligibility.
  • Review documentation and transaction flows to support offshore profits positions.
  • Advise on risks associated with offshore claims and Inland Revenue Department challenge exposure.
  • Assist in preparing representations and supporting documentation for offshore claim submissions.
  • Provide advisory support during Inland Revenue Department enquiries relating to source of profits assessments.

PRC Corporate Income Tax Advisory

  • Advisory on PRC Corporate Income Tax (CIT) implications for foreign-invested enterprises and domestic entities.
  • Analysis of cross-border service arrangements and withholding tax exposure.
  • Interpretation of PRC tax regulations affecting intercompany transactions.
  • Advisory on preferential tax policies and qualification requirements.
  • Assessment of PRC tax risks associated with inbound and outbound structuring.

Cross-Border Tax Structuring

  • Advisory on international tax structuring for multinational groups operating between Hong Kong, the PRC, and overseas jurisdictions.
  • Assessment of withholding tax implications on cross-border payments including dividends, interest, royalties, and service fees.
  • Application of Double Taxation Agreements (DTAs) and treaty benefit analysis.
  • Advisory on substance requirements, beneficial ownership considerations, and economic presence.
  • Support alignment of group tax governance across jurisdictions.

Outbound Investment Holding Structure Advisory

  • Advise PRC enterprises on structuring outbound investments through appropriate holding jurisdictions.
  • Assess tax, regulatory, and commercial implications of using Hong Kong or other intermediate holding entities for overseas expansion.
  • Evaluate withholding tax efficiency, treaty network access, and participation exemption considerations.
  • Review substance requirements and anti-avoidance exposure in selected holding jurisdictions.
  • Analyse profit repatriation pathways and cross-border cash flow structuring.
  • Advise on interaction between PRC outbound investment rules and foreign tax regimes.
  • Support restructuring of existing holding arrangements to enhance tax efficiency and governance alignment.

Hong Kong Foreign-Sourced Income Exemption (FSIE) Advisory

  • Advise on the application of the Hong Kong Foreign-Sourced Income Exemption (FSIE) regime to foreign-sourced dividends, interest, disposal gains, and intellectual property income.
  • Assess economic substance requirements applicable to in-scope multinational entities.
  • Advise on participation exemption conditions and related compliance obligations.
  • Evaluate nexus requirements for intellectual property income under the FSIE framework.
  • Review cross-border holding structures to assess exposure under anti-abuse and anti-avoidance provisions.
  • Support preparation of documentation to substantiate exemption claims under the FSIE regime.
  • Advise on restructuring considerations to align with FSIE compliance requirements.

Hong Kong–Mainland China Double Taxation Arrangement (DTA) Advisory

  • Advise on the application of the Hong Kong Foreign-Sourced Income Exemption (FSIE) regime to foreign-sourced dividends, interest, disposal gains, and intellectual property income.
  • Assess economic substance requirements applicable to in-scope multinational entities.
  • Advise on participation exemption conditions and related compliance obligations.
  • Evaluate nexus requirements for intellectual property income under the FSIE framework.
  • Review cross-border holding structures to assess exposure under anti-abuse and anti-avoidance provisions.
  • Support preparation of documentation to substantiate exemption claims under the FSIE regime.
  • Advise on restructuring considerations to align with FSIE compliance requirements.

PRC Withholding Tax & Profit Repatriation Advisory

  • Advise on PRC withholding tax implications arising from cross-border payments made by PRC entities to non-resident enterprises.
  • Assess withholding tax exposure on dividends, interest, royalties, and service fee payments to overseas shareholders or related parties.
  • Evaluate eligibility for reduced withholding tax rates under applicable double taxation agreements.
  • Review beneficial ownership requirements and substance considerations in determining treaty relief eligibility.
  • Advise on structuring alternatives for profit extraction, including dividend distributions, intercompany service arrangements, royalty payments, and capital reduction mechanisms.
  • Assess PRC tax implications of indirect equity transfers under PRC anti-avoidance and indirect transfer rules.
  • Support preparation of documentation for withholding tax filings and treaty benefit applications with PRC tax authorities.
  • Assist in managing tax authority enquiries relating to cross-border payment arrangements.

OECD Pillar Two Advisory

  • Advisory on the OECD Global Anti-Base Erosion (GloBE) Model Rules and jurisdictional implementation requirements.
  • Assessment of Hong Kong implementation of the Qualified Domestic Minimum Top-Up Tax (QDMTT) and Income Inclusion Rule (IIR), where applicable.
  • Analysis of group-level GloBE computations as they relate to Hong Kong constituent entities.
  • Review of jurisdictional Effective Tax Rate (ETR) calculations and top-up tax exposure.
  • Advisory on interaction between Hong Kong domestic legislation and global Pillar Two framework.

Cross-Border Tax Structuring

  • Advisory on international tax structuring for multinational groups operating between Hong Kong, the PRC, and overseas jurisdictions.
  • Assessment of withholding tax implications on cross-border payments including dividends, interest, royalties, and service fees.
  • Application of Double Taxation Agreements (DTAs) and treaty benefit analysis.
  • Advisory on substance requirements, beneficial ownership considerations, and economic presence.
  • Support alignment of group tax governance across jurisdictions.

Outbound Investment Holding Structure Advisory

  • Advise PRC enterprises on structuring outbound investments through appropriate holding jurisdictions.
  • Assess tax, regulatory, and commercial implications of using Hong Kong or other intermediate holding entities for overseas expansion.
  • Evaluate withholding tax efficiency, treaty network access, and participation exemption considerations.
  • Review substance requirements and anti-avoidance exposure in selected holding jurisdictions.
  • Analyse profit repatriation pathways and cross-border cash flow structuring.
  • Advise on interaction between PRC outbound investment rules and foreign tax regimes.
  • Support restructuring of existing holding arrangements to enhance tax efficiency and governance alignment.

Hong Kong Foreign-Sourced Income Exemption (FSIE) Advisory

  • Advise on the application of the Hong Kong Foreign-Sourced Income Exemption (FSIE) regime to foreign-sourced dividends, interest, disposal gains, and intellectual property income.
  • Assess economic substance requirements applicable to in-scope multinational entities.
  • Advise on participation exemption conditions and related compliance obligations.
  • Evaluate nexus requirements for intellectual property income under the FSIE framework.
  • Review cross-border holding structures to assess exposure under anti-abuse and anti-avoidance provisions.
  • Support preparation of documentation to substantiate exemption claims under the FSIE regime.
  • Advise on restructuring considerations to align with FSIE compliance requirements.

Hong Kong–Mainland China Double Taxation Arrangement (DTA) Advisory

  • Advise on the application of the Hong Kong Foreign-Sourced Income Exemption (FSIE) regime to foreign-sourced dividends, interest, disposal gains, and intellectual property income.
  • Assess economic substance requirements applicable to in-scope multinational entities.
  • Advise on participation exemption conditions and related compliance obligations.
  • Evaluate nexus requirements for intellectual property income under the FSIE framework.
  • Review cross-border holding structures to assess exposure under anti-abuse and anti-avoidance provisions.
  • Support preparation of documentation to substantiate exemption claims under the FSIE regime.
  • Advise on restructuring considerations to align with FSIE compliance requirements.

PRC Withholding Tax & Profit Repatriation Advisory

  • Advise on PRC withholding tax implications arising from cross-border payments made by PRC entities to non-resident enterprises.
  • Assess withholding tax exposure on dividends, interest, royalties, and service fee payments to overseas shareholders or related parties.
  • Evaluate eligibility for reduced withholding tax rates under applicable double taxation agreements.
  • Review beneficial ownership requirements and substance considerations in determining treaty relief eligibility.
  • Advise on structuring alternatives for profit extraction, including dividend distributions, intercompany service arrangements, royalty payments, and capital reduction mechanisms.
  • Assess PRC tax implications of indirect equity transfers under PRC anti-avoidance and indirect transfer rules.
  • Support preparation of documentation for withholding tax filings and treaty benefit applications with PRC tax authorities.
  • Assist in managing tax authority enquiries relating to cross-border payment arrangements.

OECD Pillar Two Advisory

  • Advisory on the OECD Global Anti-Base Erosion (GloBE) Model Rules and jurisdictional implementation requirements.
  • Assessment of Hong Kong implementation of the Qualified Domestic Minimum Top-Up Tax (QDMTT) and Income Inclusion Rule (IIR), where applicable.
  • Analysis of group-level GloBE computations as they relate to Hong Kong constituent entities.
  • Review of jurisdictional Effective Tax Rate (ETR) calculations and top-up tax exposure.
  • Advisory on interaction between Hong Kong domestic legislation and global Pillar Two framework.

Hong Kong Salaries Tax Advisory

  • Advisory on Salaries Tax obligations for directors and employees.
  • Assessment of taxability of benefits-in-kind and equity compensation arrangements.
  • Advisory on tax-efficient remuneration structuring.
  • Support cross-border employment tax considerations.

Hong Kong–PRC Cross-Border Employment Structuring

  • Assessment of tax residency status under Hong Kong and Mainland China rules.
  • Advisory on dual-contract arrangements and secondment structures.
  • Analysis of permanent establishment and employer withholding implications arising from cross-border staff deployment.
  • Advisory on allocation of employment income between jurisdictions.

Mainland China Individual Income Tax (IIT) Planning & Advisory

  • Advisory on Mainland China Individual Income Tax (IIT) obligations for expatriates assigned to the PRC.
  • Assessment of PRC tax residency status under the 183-day and six-year rules.
  • Planning support for tax-efficient structuring of remuneration packages, including allowances and benefits.
  • Advisory on housing benefits, relocation allowances, and tax-exempt benefit treatment under PRC regulations.
  • Review of equity compensation and share-based incentive taxation in the PRC context.
  • Analysis of double taxation exposure and availability of foreign tax credits.
  • Support coordination between Hong Kong and PRC tax positions to ensure consistency and mitigate compliance risk.

Expatriate Tax Equalisation & Mobility Structuring

  • Advise employers on tax equalisation and tax protection policies for cross-border assignments.
  • Design tax equalisation frameworks to neutralise tax differentials between home and host jurisdictions.
  • Prepare tax cost projections for inbound and outbound assignments.
  • Analyse employer tax gross-up requirements and compensation structuring implications.
  • Support coordination of individual income tax compliance across jurisdictions.
  • Advise on interaction between employer withholding obligations and expatriate tax equalisation policies.
  • Assist in documentation of tax equalisation arrangements and assignment letters.

PRC Indirect Tax Advisory

  • Advisory on PRC Value-Added Tax (VAT) implications for goods and services transactions.
  • Guidance on VAT classification, input credit entitlement, and invoicing compliance.
  • Assessment of cross-border VAT exposure and export rebate considerations.

Exit & Succession Planning

  • Advisory on tax implications of shareholder exits, business disposals, and management buyouts.
  • Structuring advisory for succession planning and ownership transition.
  • Assessment of cross-border capital gains and withholding tax exposure.
  • Support long-term tax-efficient transition strategies.

Tax Risk Review & Governance

  • Review of historical tax positions and identification of potential exposure areas.
  • Assessment of internal tax governance framework and control processes.
  • Advisory on voluntary disclosure strategies where appropriate.
  • Recommendations for strengthening tax risk management and compliance oversight.

Tax Investigation & Dispute Support

  • Advisory support during Inland Revenue Department (IRD) enquiries, field audits, and tax investigations.
  • Preparation of responses to information requests and assessments.
  • Support objection and appeal procedures.
  • Strategic assistance in managing tax disputes and settlement discussions.