Tax advisory and compliance

“How would various tax issues affect my business decisions?”

CPS Taxation Services Limited provides you with answers by offering our full range tax advisory and compliance services to help clients addressing their unique issues.

Tax issues are complicated and most of the time confusing, especially when business structures are set up in different countries with different regulatory and tax regimes, for example in Hong Kong and China. As business activities become increasingly globalized, the tax exposures of doing business abroad cannot be under-estimated, and sometimes are even over-looked unless they are properly structured in advance.

CPS Taxation Services Limited provides value-added tax advisory services to help multinational clients to proactively identify and contain tax exposures arising from their cross border business. We advise clients on potential tax planning arrangement and provide practical guidance to support client’s execution of tax initiatives so as to maximize the intended tax savings. We also ensure our clients’ tax compliance needs are satisfied by providing our full range tax compliance services.

Tax advisory services

Hong Kong offshore claim / capital gain exemption / Intellectual Property planning

  • Advising on Hong Kong tax implications and tax planning opportunities of your proposed transactions including the offshore claims
  • Advising on the documentation required and preparing “operation manual” in supporting the offshore claim, where appropriate
  • Advising on capital gain tax exemption on profits derived from disposal of assets in Hong Kong
  • Advising on tax efficient arrangement on other transactions such as acquisition, transfer and licensing of intellectual properties, cross border intercompany services and expenses allocation arrangement etc.

Cross border structuring advisory and tax planning

  • Reviewing the Hong Kong and China group structures and exploring legitimate tax arrangements to utilize group tax losses or minimize other tax leakages
  • Advising on tax efficient holding structures investing into China with built-in flexibility to facilitate future restructuring / exit as well as profits repatriation out of China
  • Advising on tax efficient investment vehicle or structure in China, including:
    • Representative Office,
    • Foreign invested commercial enterprises (FICE) for wholesaling / retailing operation,
    • buying out Chinese partners and “convert” into a Wholly Foreign Owned Enterprise (WFOE),
    • Special purpose consulting or service WFOE,
    • Converting contract processing factories into manufacturing WFOEs,
    • Chinese investment holding structure etc;
  • Reviewing of and advising on intended business operation and licensing requirements in China
  • Advising on the thin-capitalization rule in China to explore tax efficient funding structures and tax planning to minimize the PRC withholding tax

Tax treaty advisory

  • Reviewing of and advising on tax treaty benefits available to the repatriation of dividend and other passive income as available under the respective tax treaty
  • Advising on the requirements to maximize the tax treaty benefits as identified, including the relevant substance assessments, beneficial owners rules and commercial justification
  • Advising on the relevant application procedures applicable to non-residents in order to secure the tax treaty benefits

Hong Kong / China tax health check review

  • Performing tax health check review to ensure the Hong Kong / China operations are in compliance with relevant tax regulations
  • Highlighting potential non-compliance practices, suggesting practical rectifications, and identifying planning areas to improve overall tax efficiency

International assignment advisory

  • Advising on the individual tax implications on international mobilization of foreign secondees to Hong Kong / China, Hong Kong-based employees travelling and working across the border
  • Reviewing the corporate permanent establishment exposure upon the international posting of secondees and ways to mitigate the exposures
  • Designing and reviewing secondment policy and employment contracts, advising on the implementation of tax equalization / tax protection policy and preparing necessary home and host country statutory filings etc

Transfer pricing advisory

  • Advising on intercompany transactions from a transfer pricing perspective including the review of risks and of returns allocation on the value chain and re-assignment / restructuring to satisfy the arms-length basis
  • Performing benchmarking and transfer pricing documentation to ensure tax compliance

Merger & Acquisition (M&A) support

  • M&A transaction supports, including due diligence review, deal negotiation supports; review of the draft contracts
  • Confirming or lobbying of tax treatments with tax authorities
  • Advising on exit clause, warranty and representation terms etc from tax perspectives

Foreign contractors

  • Advising on tax efficient means for foreign business carrying out construction-related contracts, equipment supplies, installations and technical service supplies in China;
  • Assistance with registration with competent authorities, negotiation on a favorable deemed profit rate etc

Tax compliance services

  • Performing annual employers returns and tax filing for hiring and termination of employees
  • Hong Kong profits tax and individual salaries tax return filing with supporting computations
  • Reviewing tax assessment notices, advising holdover or objection applications, or re-opening of tax assessments
  • Reviewing tax enquiries issued by the tax authorities and preparing reply letters for clients
  • Tax audit support including representing clients to handle tax enquiries, proposing compromise settlement and meeting with tax authorities
  • Preparing monthly / quarterly and annual tax return filings according to the China tax rules.

You are welcome to approach CPS Taxation Services Limited to discuss our resources available to support your businesses.