香港稅收制度具有以下基本的特點:
1. 香港稅收制度以地域為徵收稅項的基礎。 只對來自香港的利潤及收入徵稅。 來自香港境外的利潤及收入一律都不進行徵稅,即使這些利潤及收入在香港流通過。
2. 在香港境內,依靠任何形式經營活動的法人,都需要在香港繳納利得稅。 法人包括在香港註冊的公司、法團、合夥商號、信託人或團體。
3企業納稅年度發生的虧損,准予向以後年度結轉,用以後年度的所得彌補,但結轉年限最長不得超過五年。 當彌補以前年度虧損為零時,利得稅才進行徵收。
4. 香港利得稅的稅率是定額稅率。 香港利得稅稅率為16.5%、不過對於年收入低於400萬美元的小微企業,香港稅局對其進行優惠,利得稅稅率減至8%這實際上是世界上最低的利得稅稅率。
我司的專業人士能作為您的稅務代表. 説明您瞭解稅務知識,並運用其獲得最大優惠。
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
