* This is a final tax applicable to persons not carrying on business in Hong Kong. The general withholding tax rate is 4.95% for payments to corporations. For payments to individuals (including unincorporated businesses), the general withholding tax rate is 4.5%. However, if a recipient of payments is an associate of the payer and if the intellectual property rights were previously owned by a Hong Kong taxpayer, a withholding tax rate of 16.5% applies to payments to corporations and a 15% rate applies to payments to individuals (including unincorporated businesses).
While the economic recession has affected the market for professional tax services in Hong Kong, during 2009 firms have continued to act for many clients on an array of projects and transactions, many of which have been headline news in the territory ...
[more]
While the economic recession has affected the market for professional tax services in Hong Kong, during 2009 firms have continued to act for many clients on an array of projects and transactions, many of which have been headline news in the territory or the region. There has been a strong demand for international tax planning services from Chinese companies seeking to invest abroad. The new Income Tax Law in China, and the constant stream of related regulations and circulars, are also strong areas of activity. The financial crisis itself is also giving rise to a demand for services, with many companies seeking to restructure their funding arrangements, including retiring or replacing expensive debt funding with cheaper alternatives. Many companies are also seeking assistance in the areas of hedging and foreign exchange management and in ways to "monetise" the operating losses that they may have suffered as a consequence of the downturn.
Likewise, services related to transfer pricing particularly in connection with China's new transfer pricing documentation requirements, continue to be in high demand. Firms are also experiencing a demand for Hong Kong-related transfer pricing services. It is expected this will also be an area of further growth in the future as the Hong Kong tax authorities become more focused on this area and as Hong Kong expands its tax treaty network.
For years, Hong Kong's Inland Revenue Department treated foreign multinationals with "kid gloves" due to the fear that they would struggle to comply with the complex tax system. But now, as revenue has dried up, the authorities have ditched the gloves and have begun prodding the multinationals on the off-chance that they will give them some much-needed money.
[hide]