Raymond Yeung Tax Consultant former Assessor of Inland Revenue Department 前稅局評稅主任楊輝洪

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Profits Tax - Source of manufacturing profits

From my experience, the Revenue's lines of practice are as follows:

The source of profits of a manufacturing concern is the location of the factory. In other words, if goods  are manufactured in Hong Kong, the profits from the sale will be fully taxable. This is because the profits are derived from the manufacturing operation  done in Hong Kong. 

If goods are manufactured partly in Hong Kong and partly outside, that part of the profits attributable to the manufacturing outside Hong Kong is not taxable. The place of sale is unimportant.

Nowadays, many Hong Kong manufacturers set up factories in mainland with a mainland enterprise. Usually, the Hong Kong manufacturer provides capital, materials, technical knowledge, management, training, supervision... etc. On the other hand, the mainland party provides land and labor. In general, with a view to avoiding tax disputes, the Revenue accepts Apportionment of profits from the sale of the manufactured goods between Hong Kong source and non-Hong Kong source on a 50:50 basis --- that means only 50% of the profits are assessable.

If the manufacturing is contracted to an independent sub-contractor in mainland and the Hong Kong company plays little part in the manufacturing, then the Revenue may accept the profits from the manufacturing as not assessable. Nevertheless, the profits made by the Hong Kong concern from the sale of the goods are still taxable. 


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