Cross Border Corporate Tax
Expert cross-border corporate tax advisory for Hong Kong and Asia-Pacific businesses covering profits tax, offshore claims, and international structuring.
Our Cross Border Corporate Tax Services
Hong Kong Profits Tax Advisory
- Advising on the scope and application of Hong Kong profits tax
- Structuring operations to optimise the territorial source principle
- Preparing and supporting offshore profits tax claims
- Managing Inland Revenue Department enquiries on source of profits
- Advising on deemed trading receipts and anti-avoidance provisions
Permanent Establishment and Substance
- Assessing permanent establishment exposure across Asia-Pacific jurisdictions
- Advising on substance requirements for holding and operating entities
- Structuring management and control arrangements to manage tax residency
- Supporting compliance with economic substance regulations in relevant jurisdictions
International Holding and Group Structures
- Designing tax-efficient holding structures through Hong Kong
- Advising on intermediate holding company arrangements for regional operations
- Reviewing and restructuring existing group structures for tax optimisation
- Advising on financing arrangements and intercompany transactions
Transfer Pricing Compliance
- Preparing and reviewing transfer pricing documentation
- Advising on arm's length pricing for intercompany transactions
- Assisting with advance pricing arrangement applications
- Managing transfer pricing aspects of cross-border restructurings
Double Taxation Agreement Network
- Identifying and securing treaty benefits across Hong Kong's expanding DTA network
- Advising on treaty eligibility, limitation on benefits, and anti-treaty shopping provisions
- Coordinating with overseas counsel on cross-border treaty applications
- Assisting with mutual agreement procedure requests
BEPS and International Compliance
- Advising on the impact of OECD BEPS measures on Hong Kong operations
- Assisting with Country-by-Country Reporting obligations
- Reviewing structures for compliance with anti-hybrid mismatch rules
- Monitoring and advising on evolving global minimum tax requirements
Our Approach
Technically Rigorous Analysis
Commercially Focused Solutions
Coordinated Cross-Border Execution
Proactive Risk Management
