International Tax Advisory & Cross-Border Structuring

In an increasingly complex and rapidly evolving global tax landscape, businesses require a practical, forward-looking, and well-structured approach to compliance, risk management, and cross-border tax planning. Our experienced tax advisory team assists multinational groups, mid-market enterprises, and growth-oriented businesses in managing their international operations efficiently while maintaining compliance with applicable local tax regulations, international tax standards, and OECD BEPS 2.0 requirements.

Our firm is well positioned to support clients through a combination of practical Hong Kong tax experience and a strong international perspective. We provide commercially focused advice on cross-border tax matters, transfer pricing, treaty access, OECD BEPS 2.0, Pillar Two, and GIR-related obligations, with an emphasis on identifying tax risks, potential audit triggers, and compliance issues at an early stage. By developing a thorough understanding of each client’s business model, operating structure, commercial objectives, and stage of development, we deliver tailored, business-oriented solutions rather than standardised advice, helping clients manage tax complexity, enhance compliance, and support sustainable long-term growth in an evolving global tax environment.

Transfer pricing

We assist clients in managing intercompany transactions with transparency, robust documentation, and a structured approach designed to reduce potential tax controversy and compliance risk.

Policy Design and Planning Developing arm’s-length transfer pricing policies for tangible goods, intra-group services, financing arrangements, and intellectual property that are aligned with OECD BEPS guidelines and relevant local requirements.
Three-Tiered Documentation Preparing contemporaneous Master Files, Local Files, and benchmarking analyses tailored to applicable regional requirements, including Hong Kong’s DIPN 58 framework where relevant.

Filing of CBC report

We support Hong Kong constituent entities in assessing, preparing, and fulfilling their Country-by-Country reporting obligations in a timely, accurate, and compliant manner.

Hong Kong Applicability Assessment Assessing whether the Hong Kong entity is subject to CbC reporting or notification obligations under the Inland Revenue Ordinance, including consideration of the applicable HKD 6.8 billion consolidated group revenue threshold.
Hong Kong Data Review Reviewing the required financial, operational, and tax information of the Hong Kong entity to ensure consistency with the group’s overall CbC reporting position.
CbC Notification and Filing with the IRD Preparing and submitting CbC notifications and, where applicable, CbC returns to the Hong Kong Inland Revenue Department within the prescribed statutory deadlines.

Pillar Two Advisory, Top-Up Tax & GIR Compliance

We assist multinational groups in navigating the global minimum tax framework under BEPS 2.0, including the 15% effective tax rate requirements and related statutory compliance obligations.

GIR Filing and Compliance Assisting with the compilation, review, validation, and submission of the standardised GloBE Information Return (GIR), including the reporting of Pillar Two calculations, entity classifications, and jurisdictional information across the group.
Top-Up Tax Notifications and Returns Supporting clients in managing local top-up tax compliance obligations, including statutory notifications and return filings under the Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and Domestic Minimum Top-Up Tax or Hong Kong Minimum Top-Up Tax regimes, where applicable.
ETR Impact Assessment and Safe Harbour Analysis Performing jurisdiction-by-jurisdiction effective tax rate modelling, evaluating eligibility for Transitional CbCR Safe Harbour relief, and assisting with Pillar Two registration and related submissions through the relevant tax authority portals.

Application of Certificate of Residence

We assist clients in obtaining treaty relief and accessing double tax treaty benefits by demonstrating appropriate commercial substance and tax residency status.

Certificate of Residence Application Support Preparing and filing applications with the relevant tax authorities, such as the Hong Kong Inland Revenue Department, to support clients in securing benefits under applicable Double Taxation Agreements.
Economic Substance Analysis Evaluating local management arrangements, decision-making processes, and operational substance to help address potential treaty abuse concerns and support the application for treaty benefits.
Withholding Tax Optimisation Structuring cross-border dividend, interest, and royalty flows in a tax-efficient and compliant manner to help reduce withholding tax exposure where treaty relief or other applicable mechanisms are available.