Enjoying the benefits under tax treaty and the impact of CRS

View this page in: 繁體中文版

21 March 2019, Hong Kong

By invitation only


The developments in international tax arena in terms of transparency and alignment of business substantial have been in a rapid pace. These developments have impacts to corporations which cross-border operations or investments and the individual owners of these corporations.

To increase tax transparency between jurisdictions and ensure tax compliance, the Organisation of Economic Cooperation and Development (OECD) and the G20 put in place a global standard for automatic exchange of financial account information (AEoI) (i.e. common reporting standard, (CRS)). More than 100 jurisdictions, including British Virgin Islands, Cayman Islands, China, Hong Kong, Singapore, etc., have committed to CRS and most of these jurisdictions have completed their first exchange of financial account information of entities and individuals who are not tax resident in these jurisdictions in 2017 or 2018.  Hong Kong has completed its first exchange of financial account information, covering 75 jurisdictions, in 2018 and on 2 November 2018, Inland Revenue (Amendment) (No. 7) Bill 2018 has been gazetted to increase CRS reportable jurisdictions to 126. CRS has a wide impact to the industries, including any individuals, companies, funds and other entities that have overseas financial accounts.  

On the other hand, from a tax treaty perspective, application to Hong Kong Inland Revenue Department (IRD) for a Hong Kong tax resident certificate by both corporations and individuals has now become more challenging than ever, particularly under the Base Erosion and Profit Shifting development in recent years whereby the IRD has obviously tightened the requirement for granting a Hong Kong tax resident certificate.  At the same time, on 3 February 2018, the State Administration of Taxation (SAT) released the SAT Public Notice [2018] No.9 (Public Notice 9) which comprehensively updates the assessment principles for the determination of "Beneficial Ownership". 

  • What are the common issues for the application of Hong Kong tax resident certificate?
  • What are the IRD's views on Public Notice 9?
  • What implications do Public Notice 9 have on the application of Hong Kong tax resident certificate? 

In this seminar, our professionals will share with you:

  • the latest development and overview of CRS in China and Hong Kong, the determination of tax residency and the potential tax implications to the individual account holders;
  • the challenges and approaches in handling the application of a Hong Kong tax resident certificate; and
  • case sharing and our insights on these issues.


Event details

Date:         21 March 2019 (Thursday)

Time:         9.30am - 12.30pm (Registration starts at 9am)

Venue:       PwC Executive Conference Centre, 21/F Edinburgh Tower, The Landmark
                  15 Queen's Road Central, Hong Kong

Language:  Cantonese

Fee:            Complimentary 



For more information, please contact

Jessica Tang

Tel: +[852] 2289 5633