Cross-border structures
International Business & Asset Holding in Hong Kong
Hong Kong can anchor an Asian structure. Whether it should depends on where your activity and decisions actually sit.
GCC business setup specialists
Source is the whole question
Hong Kong’s territorial basis makes it attractive, and also makes it a jurisdiction where structures are tested. Whether profits are Hong Kong-sourced depends on where the profit-generating activity happens, not on where the company is registered.
- Substance and source expectations set out before you incorporate
- Home-country advisers co-ordinated, not ignored
- Honest about when a structure will not hold up
20+
Mainland, free zone and offshore jurisdictions we file in — so the recommendation is based on your activity, not on which authority we happen to be registered with.
7,000+
Companies successfully established.
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Settle these first
The questions that decide the structure
Answered honestly, the shortlist is short.
| Question | Why it decides the structure |
|---|---|
| Where are the owners resident? | Their home rules often matter more than Hong Kong’s. |
| Where is the work actually done? | Drives both source and substance. |
| Where are customers and suppliers? | Selling into a country can create obligations there. |
| Is this a China-facing structure? | Hong Kong’s position is specific and worth advice on both sides. |
| Will you claim offshore source? | It must be supportable with evidence, not asserted. |
| Who else must accept it? | Banks test structures hardest here. |
Cross-border treatment depends on rules in more than one country and changes. We co-ordinate with advisers elsewhere rather than opining on their law.
How it works
Working through it properly
Sometimes the answer is that Hong Kong is the wrong jurisdiction.
01
Map the facts
Residency, decision-making, where work happens, customers, and what the entity will hold or sell.
02
Options and consequences
Hong Kong options that fit, the substance each expects, maintenance cost including audit, and where you need advice elsewhere.
03
Form and document
The Hong Kong entity formed once agreed, records established, and the basis documented for banks and the IRD.
To assess properly
What we need to see
Thin information produces a structure that fails bank onboarding.
- Tax residency of each ultimate owner
- Current group structure chart
- Where directors and decision-makers are based
- Where staff and contractors actually work
- Revenue split by customer country
- Where contracts are negotiated and signed
- Assets the structure will hold
- Existing entities and jurisdictions
- Financing or investor agreements
- Advice already received at home
- Banking relationships to keep
- Timeline and what is driving it
Scope
What is included, and what is not
Stated plainly, so nothing is added once the engagement starts.
Included in the service fee
- Structured fact-gathering and options paper
- Hong Kong entity recommendation with substance expectations
- Honest assessment of any offshore source claim
- Co-ordination with your home-country advisers
- Incorporation of the Hong Kong entity
- Company secretary and registered office arranged
- Statutory records and registers
- Documented basis for the structure
Not included, quoted separately
- Tax or legal advice on non-Hong Kong law
- Formal opinions on source or treaty positions
- Transfer pricing studies
- Formation of entities outside Hong Kong
- Trust and foundation formation
- Annual audit, performed by a Hong Kong CPA
- Valuations
- Filings in other jurisdictions
Verify independently
Official Hong Kong authorities
We file directly with these bodies on your behalf.
Companies RegistryInland Revenue DepartmentImmigration DepartmentMandatory Provident Fund Schemes AuthorityIntellectual Property DepartmentCustoms and Excise Department
Questions
Hong Kong international structuring — FAQs
Will a Hong Kong company reduce my tax at home?
That depends on your home country’s rules, which we do not advise on. We will say plainly when the answer needs an adviser where you live.
Can I just claim offshore source?
No. It depends on where the profit-generating activity took place and must be supported with evidence. We will tell you when a claim is weak rather than file one that fails.
Is Hong Kong still good for China-facing business?
It remains the most used route, with its own treaty position and practical advantages. Whether it suits your group needs advice on both sides.
Will banks accept a cross-border structure?
They test them hard here. Simple, explainable structures with real activity get through; opaque ones frequently do not.
Do you form entities outside Hong Kong?
No. We handle the Hong Kong elements and co-ordinate with your advisers elsewhere.
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