Speaker(s)
- Ms Carol Lam, Director, Tax, BDO
- Mr Paul Wong, Senior Manager, Tax, BDO
Description
It is not uncommon for using a Hong Kong entity to hold PRC investments under a multinational holding structure. Dividends received by a Hong Kong entity from its PRC investments is subject to withholding tax in the PRC. It is possible to enjoy a reduced tax rate under the Arrangement between The Mainland of China and the Hong Kong Special Administrative Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income tax treaty between the Mainland China and Hong Kong (“China-HK DTA”). However, the granting of treaty benefits is not automatic and there could be hurdles and complexities that taxpayers need to overcome.
In Hong Kong, offshore claims on dividends are no longer straightforward under the new Foreign Source Income Exemption (“FSIE”) regime. China-sourced dividends received by a Hong Kong entity will be deemed as taxable with effect from 1 January 2023 unless the relevant exemption requirements are met.
If a Hong Kong entity is expected to receive dividends from its PRC investments, it is recommended to have proper arrangement in place to ensure tax efficiency could be achieved.
Two tax experts from BDO will discuss the following in this webinar:
- The treaty benefits on China-sourced dividends under the China-HK DTA.
- The “beneficial ownership” requirements and the extended “safe harbour” rules.
- PRC withholding tax obligations and procedural requirements.
- Practical issues and considerations in claiming the treaty benefits.
- Key considerations for obtaining the Certificate of Resident Status in Hong Kong.
- The Hong Kong tax impacts under the new FSIE regime for China-sourced dividends received by a Hong Kong entity and the exemption requirements.
- Cases sharing.
Level: Intermediate
Speakers' bio:
Ms Carol Lam
Mr Paul Wong
Seat guarantee will only be given to HKCGI Fellows and/or Practitioner’s Endorsement (PE) holders if registered 10 clear working days with payment prior to the date of the seminar.