Hong Kong Company Formation, Offshore Company Incorporation
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ABOUT TRUST ONLINE
Using Hong Kong Company
about Taxation
Lower tax rate in Hong Kong
No tax in Hong Kong - Offshore operation tax exemption
Trading Business
Service providing business
No tax – for Royalty income
Investing in Europe - enjoying Double Tax Agreement (DTA)
about Transaction
Lower transaction fee in selling property
about Trading
Avoid disclosing supplier information - protecting trading business
about China market
Enjoying largest benefit - using Hong Kong company as stepping stone
Using Hong Kong HSBC bank account
Acting as finance centre for international trading group
RMB bank account for China trade and business
Hedging for RMB appreciation
Investing in Europe - enjoying Double Tax Agreement (DTA)
Background
Mr. A is investing in European company, such as a French company (F Ltd);
F Ltd performs well and will remit different type of payment to Mr A every year - such as dividend, interest and royalty etc. ;
The arrangement
Mr. A forms a Hong Kong company (H Ltd) as 100% shareholder;
H Ltd is 100% shareholder of a Luxembourg company (L Ltd);
L Ltd is 100% shareholder of French company - the F Ltd;
Payment from F Ltd reaches Mr. A via L Ltd and H Ltd.
Benefit
H Ltd and L Ltd is regarded as "Twin-Company" - there is double tax agreement between HK and Luxembourg;
Luxembourg company also enjoys local tax benefit in Europe;
Withholding tax payable
by French company
If no Twin-Company structure
If used Twin-Company structure
Dividend
25%
0%
Interest
16%
0%
Royalty
33%
0%
The income received by L Ltd and H Ltd is tax free - according to their respective tax rules.
Relative Topic
FAQs > Hong Kong Company - Private Limited Company > Tax Filing > Double Taxation - Introduction