TAX
We have an extensive practice in local and multi-jurisdictional tax. We specialize in Hong Kong, PRC, Canadian and U.S. tax advice and compliance. We also incorporate international tax advice when structuring our clients’ transactions with support from our affiliates and consultants in other jurisdictions.

Our tax team services both individual and corporate clients. Whether a client is exploring the options of setting up a base in Asia Pacific or planning an investment into China, good tax advice is crucial to making the correct decisions. We tailor advice to our clients’ specific circumstances in a rapidly evolving world of enhanced information exchange. We are experienced with Hong Kong transfer pricing issues, and with helping clients to design multijurisdictional corporate group structures to achieve tax efficiency in view of income tax treaties, impact of host country taxation laws, withholding tax, substance of operations, and other legal and fiscal issues.

We are well positioned to assist with such plans at an early stage, to help assess the most tax efficient structure for a particular client, and to then implement the plan whether in Hong Kong or elsewhere in the region.

Individuals emigrating from the Asia Pacific region to higher tax jurisdictions also require good tax advice. We have over 20 years of experience in migration tax planning.
 
We present below some representative matters handled by us:

Tax Planning and Advisory

Hong Kong
  • advising the air crew union for an international airline on its members’ Hong Kong salaries tax exposure on casual layovers and longer stays
  • advising a major investment bank on Hong Kong tax matters regarding the share investment activities of a company owned by high net worth clients
  • advising U.S. company engaged in frozen meat business on Hong Kong tax matters regarding its business activities in Hong Kong and PRC
  • advising a financial data information company on any potential Hong Kong tax issues regarding its cooperation agreement with a PRC company

PRC

  • tax and transfer pricing planning advice to a cement company with global operations, including the Americas, Asia (PRC and other countries)
  • supply chain tax planning and transfer pricing advice to multinational corporation in the pharmaceutical business with operations in PRC and various countries in Asia
  • advising foreign trustees on PRC tax issues on trust formation, client intake and trust distributions to beneficiaries in PRC and elsewhere
  • advising European based F&B group on tax efficient investment plan for PRC, Hong Kong and Taiwan including repatriation and transfer pricing policy

United States

  • advising U.S. hardware manufacturer on regional tax issues in connection with its global restructuring
  • advising U.S. retail store chain on tax efficient structures for the Asia Pacific region

Canada

  • advising on all tax and structuring issues relevant to non-resident trusts with Canadian resident beneficiaries
  • advising on departure trusts established by former residents of Canada
  • advising on foreign asset reporting requirements for Canadian residents
  • advising on issues relevant to termination of trusts with Canadian resident beneficiaries
  • advising individual and corporate clients on tax efficient Canadian inbound investment structures including for the real estate, hospitality, resource and energy sectors
  • advising Canadian enterprises on tax and transfer pricing on outbound projects into China and the Asia Pacific region
  • advising clients on tax efficient planning prior to returning to reside in Canada

Other Jurisdictions

  • advising the owner of an international school on tax consequences in the sale of its interest
  • advice to the Ministry of Finance of a country in Southeast Asia, on international tax regulations and the audits of multinational corporation
  • tax planning advice to a tile and stone manufacturer with factories in Southeast Asia, and with worldwide sales distribution network
  • advising international direct selling group on its corporate tax and transfer pricing exposure in various jurisdictions and restructuring the corporate group to minimize exposure to withholding and other taxes

Tax Advocacy and Compliance in Hong Kong

  • advising corporate clients on stamp duty relief for group reorganizations and make applications for stamp duty relief
  • advising the Hong Kong subsidiary of a U.S. company on Hong Kong tax refund for excessive tax paid in previous years
  • advising a capital fund on stamp duty compliance issues regarding stock borrowing and lending

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