Certificate of
Tax Resident
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For companies operating across borders, one of the tax risks is double taxation. A common example is the need for Hong Kong companies to pay both Hong Kong and mainland taxes when doing business in the mainland. To avoid companies paying taxes on the same income, tax residents who apply to become one of them can avoid the risk of double taxation.



Certificate of Resident / Tax Resident Certificate are issued by the Hong Kong Inland Revenue Department for proofing the enterprises or individuals are Hong Kong tax residents and eligible to enjoy preferital tax treatments under Double Taxation Arrangement / Agreements.  Applications (mainland or overseas enterprises) can enjoy tax benefits after obtaining the Certificate of Tax Resident.



展群CK ® has assisted many overseas enterprises to become Hong Kong tax residents and greatly reduce Group's tax burden





After becoming Hong Kong tax residents, tax benefits include:

  • Overseas companies are entitled to a lower withholding tax on tax residents paid to Hong Kong (withholding tax)

    • Dividend - withholding tax can be reduced from 10% to 5% for PRC entities

    • Interest - withholding tax (withholding tax) can be reduced to 7% for PRC entities

    • Royalty fee - withholding tax (withholding tax) can be reduced to 7% for PRC entities

  • Hong Kong is known for its low tax rates and less tax types, and does not levy the following taxes:

    • Dividend tax

    • Interest tax

    • Royalty tax

    • Capital gain tax

    • Estate duty


  • Pay low Hong Kong's profits tax or salaries tax (tax rates are lowered than other Asian region, since 2018/19, the profits tax rate is as low as 8.25%

Before issuing Certificate of Resident / Tax Resident Certificate by the Inland Revenue Department, the IRD will identify whether the applicants (enterprises or individuals) are eligible and fulfill the conditions, such as place of incorporation, where the management or control taken place and other important tax information



展群CK ® clients are usually PRC entities and distribute dividend, interest or royalty fee to Hong Kong investment holding company.  We assist the Hong Kong entity to apply for Certificate of Resident / Tax Resident Certificate and reply the enquries letters that raised by the Inland Revenue Department .


Some mainland 100% clients do business in the mainland, but want to become Hong Kong residents (regardless of tax or personal aspects), we will work with professional immigration consultants to tax mainland enterprises in tax restructuring and thus become Hong Kong tax residents. Legal compliance to transfer profits from the mainland into Hong Kong's profits. And it will speed up the pace of their formal becoming Hong Kong residents.


This involves the professional planning of immigration consultants, tax restructuring, tax transfer pricing reports and other professional areas of cooperation.

Please note that under the international pressure, the Inland Revenue Department is now approaching a stringent approach towards the issuance of Certificate of Resident / Tax Resident Certificate.  Applicants need to present and show that their Companies have real business substance in order to convince the Inland Revenue Department.  Experienced tax representative (展群CK ®) can greatly reduce the chance of being rejected by the Inland Revenue Department.


As a professional tax firm, 展群CK ® can provide the following services :

  • 展群CK ® become tax representative and becomes the communcation bridge between our clients and the Inland Revenue Department

  • Application of Certificate of Resident / Tax Resident Certificate

  • Provide tax advice on tax restructuring

  • Implementation of tax restructuring

  • Handle Transfer Pricing Documentation

  • Work with immigration firm and assist our clients to apply as Hong Kong residents



If you wish to transfer the profits from mainland or overseas enterprises (high tax areas) to Hong Kong (8.25% low-tax areas) and transfer funds from the mainland (or other foreign exchange control areas) to Hong Kong legally, you are welcomed to email or call us.


For further information, please contact 展群CK ®:
a. Phone at (852) 3502 7392
b. Whatsapp at (852) 5227 9242
c. Email at info@ck-tax.com