香港税收制度具有以下基本的特点：
1. 香港税收制度以地域为征收税项的基础。只对来自香港的利润及收入征税。来自香港境外的利润及收入一律都不进行征税，即使这些利润及收入在香港流通过。
2. 在香港境内，依靠任何形式经营活动的法人，都需要在香港缴纳利得税。法人包括在香港注册的公司、法团、合伙商号、信托人或团体。
3企业纳税年度发生的亏损，准予向以后年度结转，用以后年度的所得弥补，但结转年限最长不得超过五年。当弥补以前年度亏损为零时，利得税才进行征收。
4. 香港利得税的税率是定额税率。香港利得税税率为16.5%、不过对于年收入低于400万美元的小微企业，香港税局对其进行优惠，利得税税率减至8%这实际上是世界上最低的利得税税率。
我司的专业人士能作为您的税务代表.帮助您了解税务知识，并运用其获得最大优惠。
Dear Partners!
We found an interesting case recently happened and published by Inland Revenue department, that we would like to share with you.
Background
(a) Company A, Company B and Company C (collectively referred to as “the HK Companies”) are companies incorporated in Hong Kong. Their respective parent companies and common ultimate holding company are incorporated outside Hong Kong.
(b) The HK Companies are principally engaged in property investment. They collectively own a commercial building for long-term investment and letting purposes.
(c) The Group, of which the HK Companies are members, adopts a sole ownership holding structure where one property holding company holds the entire interest in one property. In order to standardize property holding structure, and enhance management and operational efficiency, the Group has planned to amalgamate Company B and Company C horizontally into Company A (“the Amalgamation”).
The arrangement
(a) Company B and Company C will be amalgamated into Company A by 30 June 2017.
(b) The Amalgamation is governed by the amalgamation provisions in Division 3 under Part 13 of the Companies Ordinance (Cap. 622). The legal effect of the Amalgamation on and after the effective date of the Amalgamation includes:
(i) Company B and Company C cease to exist as entities separate from Company A;
(ii) Company A succeeds to all property, rights and privileges, and all liabilities and obligations of Company B and Company C; and
(iii) Any agreement entered into by Company B and Company C may be enforced by or against Company A.
(c) After the Amalgamation, Company A, as a sole owner, will principally and solely engaged in the rental business of the entire building.
Source : The Government of the Hong Kong Special Administrative Region Inland Revenue Department Advance Ruling Case No. 62 dated 22 August 2017
