Three layersplanned as one
Individual, corporate and trust structures planned together — salaries tax, profits tax and property tax mapped against Hong Kong's double taxation agreement network, so the whole picture stays efficient and defensible.
Planning Pillars
Browse all →Reading a DTA Side by Side
How to compare two double taxation agreements clause by clause to find the most efficient residency and source position.
Salaries Tax & 60-day Rule
Offshore Claim Profits Tax
Discretionary Trust Layering
Property Tax vs Profits Tax Election
Latest Briefs
All briefs →Welcome to Cross-border Tax Brief
跨境税务筹划综合—个人+企业+信托三层税务联动。Deloitte Tax Highlights + KPMG Global Tax Insights。
Compliance Automation for Double Taxation Avoidance: Robotic Process Automation in Tax Filing
The Hong Kong Inland Revenue Department (IRD) issued Departmental Interpretation and Practice Notes (DIPN) No. 62 in December 2024, codifying the administrat…
Crypto Asset Treatment Under CRS: Current Reporting Status for Virtual Currency Exchange Accounts
The OECD’s updated Crypto-Asset Reporting Framework (CARF) enters its first operational exchange window in 2026, yet the Common Reporting Standard (CRS) curr…
Royalty Definition in DTAs: Tax Classification of Software Payments and Technical Know-How
The OECD’s release of the 2024 update to the Model Tax Convention, specifically the revised Commentary on Article 12 (Royalties), has placed the classificati…
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