Hong Kong Incorporation

Shenzhen borders Hongkong, Hongkong enterprises to deep investment situation is very common.Since Hongkong implemented source tax jurisdiction, together with Hongkong and the mainland have signed tax arrangements, arranged according to the provisions of the Hongkong enterprises in dividends, interest, royalties and transfer of property income, enjoy preferential agreement.But this also for some countries (regions) agreement enterprises to use Hongkong as a stepping stone to “ ”, for mainland enterprises to provide possible tax interest. recently,hong kong limited company formation, bureau of Shenzhen land tax successfully blocked a case of non resident enterprises abuse of tax treaties behaviour, the amount of tax about 12000000 yuan. foreign enterprises to apply for preferential tax according to the introduction, Hongkong Mr Wong (a pseudonym) established in the Cayman Islands is a limited partnership, the company in 2007 in Hongkong to invest in the establishment of a limited liability company, legal capital of HK $10000, but the actual place of only HK $100.The company was established immediately after the Shenzhen investment company, equity ratio of 14%.In 2009, Shenzhen investment company in Shenzhen small and medium-sized board appear on the market successfully.In 2010, the Shenzhen company's legal person shares lifting of the ban, the shareholders of Hongkong company started in two levels of markets to sell shares reduction. according to the regulations, Hongkong company direct transfer of mainland companies equity (stock) and the corresponding transfer income, according to the Hongkong and the mainland to sign some tax arrangement in the transfer income to enjoy the preferential agreement.But for the specific case, the company income tax arrangement between Mainland China and Hongkong can enjoy the provisions of the agreement treatment?Tax expert for the company's proposed six questioned. Hongkong is the first company to suspicious.Hon