Hong Kong corporate tax services

With tax rules constantly changing and growing in complexity as governments respond to both local and global developments, staying compliant in Hong Kong requires expert guidance and up-to-date knowledge.

Our team of corporate tax specialists, including experts with a dedicated focus on financial services, combines deep technical knowledge with a practical, business-oriented approach. We provide tailored, commercially focused tax advice designed to address your unique requirements and help you effectively manage tax risks in an ever-changing environment. Whether you are a local enterprise or a multinational corporation, our team is fully equipped to support your needs. 

Let us help you stay ahead of regulatory changes and ensure your business remains compliant, efficient and well-positioned for success in Hong Kong’s dynamic tax landscape.

How we can help

Navigating evolving tax regulations

Every person that has carried on a trade, business or profession in Hong Kong and is required to complete a profits tax return—typically those with profits chargeable to tax, or those issued with a return by the Inland Revenue Department — must file the return by the statutory deadline. Significant penalties may be imposed for late or incorrect submissions. Navigating these obligations can be complex, especially as tax rules continue to evolve both locally and globally. Our experienced specialist team is dedicated to helping you meet your tax compliance needs efficiently and accurately, ensuring that your business remains fully compliant with all current and emerging regulations.


Transition to electronic filing

The IRD has begun implementing the electronic filing of profits tax returns in phases, with the ultimate goal of requiring all entities to e-file in the near future. This transition represents a significant change in the compliance process and may require businesses to adapt their current practices. Our experienced specialist team is dedicated to helping you meet your tax compliance needs efficiently and accurately, ensuring that your business remains fully compliant with all current and emerging regulations. To help you prepare for the shift to mandatory e-filing, we have a dedicated team ready to support you through every step of the process. 

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Proactive tax risk management

We go beyond basic compliance support. Our approach includes a thorough assessment of your tax processes to identify areas that may require additional attention or improvement. By proactively addressing potential risks and inefficiencies, we help you maintain a robust compliance framework that stands up to regulatory scrutiny. Our team also conducts comprehensive compliance health checks to identify and address any technical or procedural gaps. Leveraging advanced tax technology tools, we can automate the collection and analysis of information required for tax computations, significantly improving the efficiency and accuracy of your compliance processes.

Partner with us to ensure your tax compliance is managed seamlessly, your risks are identified and properly managed, and your business is well-prepared for the future regulatory landscape. Let our expertise and innovative solutions support your continued success.

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In recent years, the Hong Kong government has introduced a wide array of tax incentives designed to stimulate the growth and development of targeted industries, such as the patent box regime and tax concessions for family-owned investment holding vehicles. These incentives present significant opportunities for businesses seeking to enhance their competitiveness and achieve sustainable growth. However, each incentive is accompanied by a complex set of conditions and compliance requirements, which can be challenging to interpret and navigate without expert guidance.

Our team of seasoned professionals specialises in helping businesses understand and leverage these tax incentives to their fullest potential. We offer comprehensive services that include assessing your eligibility for various incentives, providing strategic advice on implementation to maximise available benefits and assisting with the necessary elections and compliance procedures.

With our in-depth knowledge of Hong Kong’s evolving tax landscape and our commitment to delivering tailored solutions, we ensure that you are well-positioned to take advantage of every opportunity. Let us help you unlock the full value of these tax incentives while ensuring compliance and managing risk.

Hong Kong operates under a territorial source principle, meaning only profits that arise in or are derived from Hong Kong are subject to profits tax. Determining the source of profits, however, is not always straightforward. Over the years, the courts have emphasised that the question of source is a practical hard matter of fact, requiring a careful examination of the specific circumstances of each case. As a result, offshore claims—where a company asserts that certain profits are not sourced in Hong Kong—are subject to close scrutiny by the Inland Revenue Department.

Adding to the complexity, Hong Kong has recently refined its foreign-sourced income exemption (FSIE) regime to better align with evolving international tax standards. Under the refined FSIE regime, specified foreign-sourced income, namely dividend, interest, disposal gains and intellectual property income—may remain non-taxable in Hong Kong when received locally, but only if specific exception conditions are satisfied. These new exception conditions are novel in the Hong Kong context and can be challenging to interpret and apply.

Our team is here to guide you through these complexities. We provide advice on the practical application of the territorial source principle, assist in preparing robust offshore claims, and help you understand and meet the relevant exception requirements. We work closely with you to analyse your business operations, review transaction flows, and ensure that your claims are well-supported and compliant with the latest rules.

Whether you are seeking to substantiate an offshore claim or navigate the intricacies of the refined FSIE regime, our specialists offer tailored solutions to safeguard your tax position. Let us help you manage risk and optimise your tax outcomes.

Hong Kong stands as a premier gateway for multinational enterprises investing into Chinese Mainland, as well as for Chinese Mainland enterprises seeking outbound investment opportunities. The city’s strategic location, robust legal framework and business-friendly environment make it an ideal jurisdiction for establishing regional holding companies. One of Hong Kong’s key advantages is the absence of withholding tax on interest and dividend, which significantly enhances the efficiency of cross-border transactions. Additionally, Hong Kong’s rapidly expanding network of double tax treaties further strengthens its position as a preferred holding company location, facilitating smoother and more tax-efficient international operations.

Nonetheless, deductions for interest and borrowing costs are subject to many practical constraints in Hong Kong. Navigating these rules requires careful planning and a deep understanding of both local and international tax implications. A well-structured funding arrangement can help secure interest deductions in Hong Kong, mitigate overall tax exposure, and enable tax-effective repatriation of cash both into and out of Hong Kong.

Our team specialises in designing and optimising holding and financing structures tailored to your business needs. We conduct comprehensive reviews of your current arrangements, identify opportunities for tax efficiency, and develop strategies that align with your commercial objectives. Whether you are looking to establish a new holding company, restructure existing operations, or enhance your financing arrangements, we provide practical solutions that address both Hong Kong and overseas tax considerations.

With our extensive network of offices and experienced professionals, we are equipped to assess the cross-border implications of your structure and ensure compliance with the latest regulatory developments. Let us help you unlock the full potential of Hong Kong as your regional hub, optimise your tax position, and support your growth ambitions in Asia and beyond.

Contact us

Jenny Tsao

Jenny Tsao

Consumer Markets Tax Leader, PwC Hong Kong

Tel: +[852] 2289 3617

Charles Chan

Charles Chan

Partner, PwC Hong Kong

Tel: +[852] 2289 3651

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