Changes to the tax laws of Hong Kong
The Hong Kong Special Administrative Region (HKSAR) Government wants more multinational enterprises (MNEs) to call Hong Kong home. Recent financial budgets have contained important tax initiatives to encourage MNEs (including Chinese enterprises) to establish their asset management businesses, corporate treasury centers and intellectual property holding hubs in Hong Kong. Under existing Hong Kong tax law, income earned by a group treasury company from its ordinary course of corporate treasury management and money lending activities carried out in Hong Kong is subject to profits tax at the rate of 16.5%. However, any interest payment made by such a group treasury company to its overseas group companies is not tax deductible because such interest is not chargeable to Hong Kong profits tax in the hands of the overseas recipients. This asymmetrical tax treatment has resulted in Hong Kong being a less attractive location for corporate treasury operations. In the 2016 Budget, the Financial Secretary also sought to provide a more commercially friendly environment for operating an intellectual property (IP) hub in Hong Kong, with a view to attracting MNEs to hold their IP in Hong...