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FAQ for the Qualifying Corporate Treasury Centre in Hong Kong

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The concessionary tax rate for a qualifying corporate treasury centre is 50% of the profits tax rate if a corporation provided that the prescribed conditions are satisfied. The following are the frequently asked questions in this regard:

Q:
What is a qualifying corporate treasury centre (“QCTC’)?
A: A corporation is a QCTC for a year of assessment if:
1.
it has carried out in Hong Kong one or more corporate treasury activities, but it has not carried out in Hong Kong any income-generating activity other than a corporate treasury activity;
2. it has carried out in Hong Kong one or more corporate treasury activities and income-generating activity other than a corporate treasury activity, but it has satisfied the safe harbour rule under section 14E of the Inland Revenue Ordinance (“IRO”); or
3. it is a CTC which the Commissioner has determined under section 14F(1) of the IRO to be a QCTC even though it satisfies neither of the conditions in (a) and (b) above.

Please note that a financial institution is not eligible to be a QCTC.

Q:
What is meant by “corporate treasury activity”?
A:
Corporate treasury activity is defined as:
1.
carrying on an intra-group financing business;
2. providing a corporate treasury service; or
3. entering into a corporate treasury transaction.

Q:
What is the benchmark of carrying on an intra-group financing business?
A:
Generally, Commissioner of the Inland Revenue Department would accept that a corporation is carrying on an intra-group financing business if:
1
the corporation has not less than four borrowing or lending transactions each month;
2. each borrowing or lending transaction exceeds HK$250,000; and
3. borrowing or lending transactions are with not less than four associated corporations in the relevant basis period.

Q:
Once a corporation satisfies the conditions of a QCTC, will all of its assessable profits be taxed under concessionary tax rate?
A:
Even though a corporation satisfies the conditions of a QCTC, profits derived from the following corporate treasury activities will be taxed under profits tax at full tax rate:
1.
intra-group financing transaction under which money is lent to a Hong Kong associated corporation;
2. corporate treasury service which is provided to a Hong Kong associated corporation;
3. corporate treasury transaction that is related to the business of a Hong Kong associated corporations; and
4. corporate treasury transaction that is not related to the business of an associated corporation.

Q:
Do QCTC still qualify for the two-tiered profits tax rates?
A:
No. A QCTC who has made the election under for the concessionary tax rate will not qualify for the two-tiered profits tax rates.

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