Certificate of Resident Status (“CoR”)

A Certificate of Resident Status is a document issued by the Hong Kong Inland Revenue Department (“HKIRD”) as a proof of resident status to a Hong Kong resident for enjoying tax benefits under the Comprehensive Double Taxation Agreements / Arrangements (DTAs).

A Hong Kong tax resident could usually enjoy preferential tax rates stipulated in the DTAs for the following income:

• Dividend;
• Interest;
• Royalties; and
• Technical fees

Under the pressure of counter party, the HKIRD is more stringent in issuing the CoR to the applicant. Applicant is required to have solid business substance in Hong Kong in order to obtain the CoR from the HKIRD.

We are experiences in assisting our client to build up business substance in Hong Kong and applying the CoR from the HKIRD.  Our services include:

• Feasibility study and planning
  • Examine the current operation and presence of a company in Hong Kong from the perspective of applying CoR;
  • Provide recommendations on building up / strengthening its substance in Hong Kong;
  • Provide support on the implementation works; and
  • Closely liaise with the management throughout the whole process.
• Application of CoR
  • Review the information and documents in connection with the business substance in Hong Kong;
  • Prepare an explanation letter detailing the operation and business presence of the applicant in Hong Kong with documentary evidence;
  • Prepare the stipulated application form to the HKIRD;
  • Reply the enquiry letter issued by the HIRD in respect of the application of the CoR; and
  • Liaise with the case officer of the HKIRD throughout the whole application process.