未雨绸缪

近年来,中国的综合国力不断提升,日趋频繁的贸易活动也加强了国际人才流动的必要性。不论是为了下一代的教育或是营商,申请一个海外的身份或居留权的优势变得越来越明显。富德林综合了部分主流国家的居留项目,从法规、税务、申请手续等不同方面提供了分析。

欢迎细阅附件的信息,并随时与我们联系info@fidinamgw.com

Dubai_Residency_by_Incorporation

Preferential Hong Kong Salaries Tax treatment on provision for rent-free or subsidized accommodation

Under current prevailing Hong Kong tax law, for an employer provides rent-free or subsidized accommodation to the employee, or for the employer wholly or partly reimburses the rent paid by the employee under a lease entered by the employee, instead of taxing the employee on the actual amount of rent paid or reimbursed by the employer, the Inland Revenue Ordinance specifies a calculation of rental value (“RV”) to be treated as taxable value of housing.

To compute the RV, rent paid by the employee to the employer or the landlord can be deducted to arrive at the RV.

The RV is calculated at 4%, 8% or 10% (*) of his/her total net income from the employer and the associated corporation after deducting outgoings and expenses (excluding expenses of self-education), depending on the type of accommodation provided.

(*): Depends on the types of accommodation

However, if the employer does not control how the employee would spend the money or has not exercised proper control over the expenditures, the Assessor will regard the reimbursements as cash allowance and include the full amount as income in the Assessable Income.

Proper control means;

  • a clearly defined system is in place, under which the ranks of those officers who are entitled to rental reimbursements and the limit of their respective entitlements are clearly laid down;
  • mode of housing benefit entitled by the employee and the limit of rental reimbursement are clearly specified in the contract of employment;
  • employer will examine the tenancy agreement and rental receipts and verify the actual payment of rent against the tenancy agreement at regular intervals, and also retain the relevant documents for record purpose.

Simple illustration for tax saving under preferential treatment on rent-free accommodation vs housing allowances:

For the year of assessment from 1 April to following 31 March;

  • A has a total salary of HKD1,000,000
  • Preferential treatment: His employer pays for his housing at a flat leased under the employer name at a total cost of HKD500,000 or
  • Housing allowance: His employer pays a housing allowances of HKD500,000

Mr. A’s total income subject to Hong Kong salaries tax is:

Preferential treatment on rent-free accommodation (HKD)

Housing allowances (HKD)

Salary

1,000,000

1,000,000

Rental Value of Accommodation, 10% on all other income (in this case 1,000,000)

100,000

Housing Allowance

500,000

Total Assessable Income

1,100,000

1,500,000

As can be seen by comparing the two, although the total costs of the employer is the same, being HKD1,500,000, the assessable income of the employee is significantly reduced when it is determined that the employer is providing accommodation to the employee.

For any tax advice in relation to the above, we are happy to assist.

Fidinam (Hong Kong) Limited
Room 1501, Prosperity Tower
39 Queen’s Road,
Central, Hong Kong
Tel:(852) 2110 0990
Email: tax@fidinam.com.hk

Business ties between Switzerland and China

The Free Trade Agreement signed between Switzerland and China entered into force in July 2014 certainly contributed to create stronger economic ties between the two countries. However, as Fidinam Group Worldwide Vice Chairman, Mr. Paolo Balen explains during a recent interview, the real competitive advantage of Switzerland relies in the great value the Chinese business partners associate to the « Swiss made » brand.

Learn more about the topic thanks to the interview released by Mr. Paolo Balen to Rete Uno Radio Svizzera Italiana. The interview has been carried out by Mr. Guido Santevecchi, news correspondent from Beijing working at Corriere della Sera and Mr. Jean-Philippe Béja, political analyst and director at The National Center for Scientific Research (CNRS) in France.

Tax implication of the french new President election

On the 7th May 2017, France has elected Emmanuel Macron as its new President. The latter already introduced a project of taxation reform which foresees to change the current tax environment, beginning with the French wealth tax (ISF) and the passive income tax.

The wealth tax reform, from 2018

The wealth tax should become the real-estate wealth tax (ISI) and would only target property assets, offering a tax relief on movable assets held by French tax payers. This reform intends to cease penalizing investment in the national economy by the housing tax exoneration for 80% of the population, that would be supported by an increase of the general social contribution (from 8.2% to 9.9%).

The revision of passive income taxation

The government also wishes to simplify the complex passive income tax system, replacing the current progressive rate by a “flat rate” (single fixed sampling) of 30%, including social contributions. The revision concerns incomes generated on interests, dividends, capital gains, life-insurance contracts and traditional savings accounts. On the other hand, the reform should not trigger modifications on the tax regime of Savings Plan for Action (apart from the general contribution rise mentioned above), nor on special saving accounts (i.e. Livret A).

French attractiveness for corporations and individuals

The President has pledged to cut the corporate income rate to 25%, instead of 33.3%, by the end of his five-year mandate.  A way to promote French attractiveness for corporate organization, to stimulate business opportunities and thus expatriation to France. Following the PLF 2017 (Finance Law Project) and the article 155B of the CGI (French Tax code), the foreign employees and executives willing to work in France benefit from a specific and advantageous tax regime. This include tax exemption on the foreign part of their income, on their repatriation premium and on their salary during the 8 years following their employment.

Implementation of UBO register

A directive from the European Union has been implemented on August the 1st 2017 in the French domestic Law, aiming to strengthen the AML (Anti-Money Laundering) regulation and the prevention of financial terrorism. The decree introduces new obligations for entities already registered under the French registry (RCS) to provide information about their Ultimate Beneficial Owners (UBO). Companies incorporated after the 1st August 2017 shall directly identify and register their UBO. This new regulation also applies to French branches of foreign companies, non-listed French enterprises or economic interest groups that have their registered seats in France, as well as legal entities that will register an entity in France. Legal entities that were incorporated before 1st August 2017 need to declare their Ultimate Beneficial Owners by 1st April 2018.

Nicolas Michaux
Managing Director Fidinam Hong Kong

Fidinam Hong Kong
Room 1501, Prosperity Tower
39 Queen’s Road Central
Hong Kong
Tel: 852 2110 0990
Email: nicolas.michaux@fidinam.com.hk

FIDINAM: Guest speaker at the Belt and Road Salon, Qingdao (China)

Jointly organised by the HKTDC and MOFCOM between the 3th  and the 5th of July 2017, the Belt and Road Salon in Qingdao promoted Hong Kong as a super-connector in China outbound investment. More than 100 enterprises from Shandong participated.

Delegates shared their experiences on the opportunities and challenges when expanding their business footprints in the emerging markets. Fidinam has been invited as a guest speaker and explained how to structure their OBOR investment via Hong Kong, Singapore and the UAE with our local offices.

Find out more from the official press release: http://qingdao.mofcom.gov.cn/article/dongtai/201707/20170702605050.shtml (Chinese)

Fidinam: Sponsor of UltraVault inaugural event

We are glad to share the photographs of the recently organized, inaugural UltraVault event, jointly sponsored by Fidinam Group.

The event was a great success, for both organizers and guests.

Gold and Diamond experts explained the benefits of precious metal investment to the attendees and provided insights on private vaults and depository solutions.

Fidinam: Sponsor of the China Offshore Summit 2017

The recent participation at the China Offshore Summit 2017 taking place in Shenzhen has been a great opportunity for our group of delegates to promote Fidinam’s worldwide operations.

By belonging to the circle of companies that sponsored the event, Uny Chan, Manager at the Swiss Desk of Fidinam Hong Kong, had the chance to step on stage and present Fidinam in front a wide audience of international companies and Family Offices

 

 

 

 

 

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