The AFP Group was incorporated to assist clients establish and grow their businesses in Asia and to provide Asian clients with the knowledge to enable them to expand into international markets. We make no apologies for the complexities of some of the structures that we may propose as this reflects the complexities of the businesses themselves. Indeed, the necessity for the exercise of such care and caution also reflects the more aggressive attitude of foreign governments towards the collection of tax as a step towards balancing their national budgets.
In Hong Kong we have noted that the Inland Revenue Department are becoming far more reluctant to agree to taxpayers’ offshore claims, whether it be in relation to offshore manufacturing, trading or even profits booked in Hong Kong through re-invoicing structures. Frequently, comprehensive requests are made for documentary proof of such claims which again underlines the necessity to carefully review a client’s business model prior to contemplating a reorganisation to reduce domestic or foreign tax.
Hong Kong has entered into a number of comprehensive double taxation treaties with other countries and continues to negotiate more. Yet with each treaty comes an exchange of information clause and the need to understand how the two jurisdictions will share the tax spoils. Transfer pricing agreements between Hong Kong and third party jurisdictions will become more and more important as foreign jurisdictions question taxpayers’ inter-company pricing models.
Whilst the development of a tax treaty network gives more credence to Hong Kong being the jurisdiction of choice for establishing a regional head office it is the Inland Revenue Department’s draconian attitude towards change that casts a shadow over, what is otherwise, a compelling argument.
Similar observations can be made of Hong Kong’s salary tax regime in that the Inland Revenue Department is increasingly reluctant to accept the concept of dual contracts and apportionment under offshore contracts.
A material percentage of the businesses located in Hong Kong and Singapore are focused on India and China trade. These markets are as attractive from a business standpoint as their tax systems are difficult to understand. Knowledge of their foreign exchange regulations, in addition to their corporate and individual tax laws, are essential for the successful implementation of a business strategy.
It can be readily appreciated that a corporate services provider needs an experienced tax capability if it is to provide the services clients demand. We at AFP, understand this and have assembled a team of tax professionals who have had years of experience with the major accounting and law firms. Our ability to advise on both international and domestic tax issues has been fundamental to our clients’ success and to their relationship with AFP.
Not only do we provide tax services to our corporate service clients but also to businesses and individuals whose own professional advisors do not have the necessary tax capability or alternatively are seeking a second opinion.
We will continue to develop our strategy as we strongly believe that the need for high quality professional tax advice will only increase as cross-border trade and investment continues to grow.
Please feel free to contact our tax department, no problem or project is too complex.