Tax substance - HKWJ Tax Law

Economic Substance in Hong Kong

It is sometimes argued that a company incorporated under HK Law (“HK Co”) will (a) automatically be regarded as a Hong Kong tax resident; and (b) only be subject to corporate tax in Hong Kong but not in other tax jurisdictions. However, one has to be well aware that if HK Co lacks (has insufficient) ‘tax […]

transfer pricing in Hong Kong & China - HKWJ Tax Law

Transfer Pricing in Hong Kong and Mainland China

Transfer pricing (“TP”) refers to the setting of prices for transactions of goods, services and intangible property between associated enterprises. Transfer pricing remains one of the most important issues in the world and is closely tied to other areas of international conflicts, like double taxation. It is about how governments treat the pricing policies enterprises […]