90%的老板都上当，为避税扎根香港，反而更亏钱，问题出在这两点

Core Viewpoint - The article emphasizes that establishing a company in Hong Kong is not merely about tax savings but requires a deep understanding of the tax system, identity, and structural logic behind it. Many businesses fall into traps due to misleading information from agents who focus only on the benefits without addressing compliance risks [2][5][23]. Tax System Insights - Hong Kong's tax system is fundamentally different from mainland China's, where businesses face multiple layers of taxation. In contrast, Hong Kong has a simplified tax structure with no value-added tax and only one profit tax, which is tiered at 8.25% for profits up to HKD 2 million and 16.5% for profits above that [11][13]. - The compliance costs in Hong Kong are lower, allowing businesses to focus more on operations rather than tax management, which is a significant advantage for companies [13][23]. Compliance and Structural Requirements - To benefit from offshore income tax exemptions, a Hong Kong company must conduct "core income-generating activities" in Hong Kong, including decision-making, contract signing, and financial management, along with having a physical office and local employees [7][9]. - Companies must also be aware of cross-border operational requirements, such as the need for ODI filing for mainland enterprises investing in Hong Kong, which has new requirements starting in 2025, including the submission of "cross-border tax compliance certificates" [9][21]. Identity and Tax Residency - There is a common misconception that obtaining Hong Kong permanent residency automatically qualifies one as a tax resident. Tax residency is determined by factors such as the duration of stay and economic ties to Hong Kong [17][19]. - To enjoy reduced withholding tax rates on dividends from mainland companies, a Hong Kong company must hold at least 25% of the shares for over 12 months and meet economic substance requirements [15][17]. Practical Steps for Implementation - Businesses must align their identity goals with economic substance when establishing operations in Hong Kong. This includes securing an office address and local employees before applying for permanent residency if they aim to benefit from dividend tax reductions [19][21]. - It is crucial to ensure that all cross-border transactions are legitimate and well-documented to avoid issues with tax authorities, as any perceived "shell transactions" could lead to tax adjustments [21][23].