Tax issues are complicated and most of the time confusing especially with cross border businesses established in different jurisdictions where different regulatory and tax regimes apply, for example Hong Kong and China.
As business activities become increasingly globalized, the tax exposures of doing business abroad shall not be under-estimated, if not being over-looked. The intensity of the global tax and regulatory developments have accelerated the requirements for competent tax advice on a going-forward basis.
We advise clients on potential tax optimal arrangement and provide practical guidance to support the execution of defined tax initiatives and realization of the commercial and financial benefits. We also ensure our clients' compliance status are monitored to mitigate un-known corporate and individual tax risks.
TAX ADVISORY SERVICES
Hong Kong offshore claim/ capital gain exemption / IP planning
- Hong Kong tax implications and planning opportunities of your proposed transactions including the offshore claims
- Documentation requirements and protocols to follow in supporting the offshore claim as appropriate
- Capital gain tax exemption from disposal of assets in Hong Kong
- Tax optimal arrangement on business acquisition, transfer and licensing of IP, cross border, intercompany/mobility services and expenses allocation arrangement etc.
Cross border structuring advisory and tax planning
- Hong Kong and China group structures review and legitimate tax arrangements to utilize group tax losses or minimize tax leakages
- Tax efficient holding and operating structures investing into China with built-in flexibility to facilitate future restructuring/exit, profits repatriation and remittance strategies
- Tax investment vehicles or structures in China
- Thin-capitalization rule in China and tax efficient funding structures to minimize PRC withholding tax
Tax compliance services
- Annual employers returns filing;
- Profits tax filing for hiring and individual salaries tax return filing with supporting computations
- Re-opening and correction of prior years tax assessments
- Tax enquiries and tax audit support
- Monthly / guarterly and annual tax return filings in China.
Hong Kong / China tax health check review
- Tax health check review to ensure the Hong Kong / China operations are in compliance with relevant tax regulations
- Investigation of non-compliance practices, practical rectifications and planning to improve overall tax efficiency
International assignment advisory
- Individual tax implications on international mobilization of foreign secondees to Hong Kong / China, Hong Kong-based employees travelling and working across the border
- Corporate permanent establishment exposure minimization and tactics
- Secondment policy and employment contracts review, implementation of tax equalization / tax protection policy, home and host country statutory filings etc
Merger & Acquisition (M&A) support
- M&A transaction supports, including due diligence review, deal negotiation supports; review of the draft contracts
- Confirmation and lobbying of tax treatments with tax authorities
- Exit clause, warranty and representation terms and tax considerations
Tax treaty advisory
- Tax treaty benefits to income repatriation
- Requirements to maximize the identified tax treaty benefits, including the substance assessments, beneficial owners rules and commercial justifications
- Application procedures applicable to non-residents to secure tax treaty benefits
Transfer pricing advisory
- Review of transfer pricing risks and returns allocation on the supply/value chain, re-assignment/restructuring to enhance arms-length justifications
- Benchmarking and transfer pricing documentation to fulfill local tax compliance