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FAQ on Two-tiered Profits Tax Rates Regime



FAQ on Two-tiered Profits Tax Rates Regime | Bestar
FAQ on Two-tiered Profits Tax Rates Regime | Bestar


FAQ on Two-Tiered Profits Tax Rates Regime in Hong Kong


What is the Two-Tiered Profits Tax Rates Regime?


The Two-Tiered Profits Tax Rates Regime in Hong Kong offers a reduced tax rate for the first HK$2 million of assessable profits for corporations and unincorporated businesses. This is designed to provide tax relief to small and medium-sized enterprises (SMEs).   


What are the tax rates under the two-tiered system?


  • Corporations:

    • First HK$2 million: 8.25%   

    • Profits above HK$2 million: 16.5%   


  • Unincorporated businesses (sole proprietorships and partnerships):

    • First HK$2 million: 7.5%

    • Profits above HK$2 million: 15%


Which entities are eligible for the two-tiered rates?


All Hong Kong corporations and unincorporated businesses are eligible for the two-tiered rates, provided they meet the general requirements for profits tax assessment.   


How does the two-tiered system work for groups of connected entities?


If multiple entities are connected, they are treated as a single entity for the purpose of applying the two-tiered rates. This means that the combined assessable profits of the group will be considered to determine the applicable tax rate.   


Can a foreign company benefit from the two-tiered rates?


Yes, a foreign company carrying on business in Hong Kong through a permanent establishment or branch can benefit from the two-tiered rates.


How does the two-tiered system interact with other tax incentives in Hong Kong?


The two-tiered system can be combined with other tax incentives available in Hong Kong, such as the Qualifying Captive Insurance Company (QCIC) regime and the Profits Tax Exemption for Certain Approved Innovation Technology Centers (AITCs).


Are there any specific requirements or conditions for claiming the two-tiered rates?


There are no specific requirements or conditions other than meeting the general requirements for profits tax assessment.


When does the two-tiered system take effect?


The two-tiered system has been in effect since the 2018/19 assessment year.   


FAQ on Illustrative Examples of the Application and Computation of Two-Tiered Profits Tax Rates


Here are some common questions and illustrative examples regarding the application and computation of the two-tiered profits tax rates in Hong Kong:


Basic Calculations


  1. Single entity with assessable profits below HK$2 million:


    • Example: A corporation has assessable profits of HK$1,500,000.

    • Calculation: 1,500,000 * 8.25% = HK$123,750 tax payable.


  2. Single entity with assessable profits above HK$2 million:


    • Example: A corporation has assessable profits of HK$3,000,000.

    • Calculation:

      • First HK$2 million: 2,000,000 * 8.25% = HK$165,000

      • Remaining HK$1 million: 1,000,000 * 16.5% = HK$165,000

      • Total tax payable: HK$165,000 + HK$165,000 = HK$330,000


Group of Connected Entities


  1. Consolidated assessment: If a group of connected entities is subject to consolidated assessment, the combined assessable profits are used to determine the tax rate.


    • Example: A group of connected entities has combined assessable profits of HK$2,500,000.

    • Calculation: 2,000,000 8.25% + 500,000 16.5% = HK$206,250 tax payable.


Carry-forward of Losses


  1. Offset against profits: Carry-forward losses can be offset against current year's assessable profits before applying the two-tiered rates.


    • Example: A corporation has assessable profits of HK$3,000,000 and carry-forward losses of HK$1,000,000.

    • Calculation:

      • Adjusted assessable profits: 3,000,000 - 1,000,000 = HK$2,000,000

      • Tax payable: 2,000,000 * 8.25% = HK$165,000


Provisional Tax


  1. Estimated assessable profits: Provisional tax is calculated based on estimated assessable profits.


    • Example: A corporation estimates its assessable profits for the upcoming year to be HK$2,500,000.

    • Calculation: 2,000,000 8.25% + 500,000 16.5% = HK$206,250 provisional tax payable.


For more detailed information and specific examples, please refer to the Inland Revenue Department's official website:



How Bestar Can Help


Bestar can provide invaluable assistance in navigating the complexities of tax laws and regulations. Here are some ways we can help:


Tax Compliance


  • Accurate filing: Ensuring that tax returns are filed correctly and on time, avoiding penalties and interest.

  • Recordkeeping: Advising on proper recordkeeping practices to support tax claims and deductions.

  • Tax audits: Representing individuals or businesses during tax audits, providing expert advice and guidance.


Tax Planning


  • Deductions and credits: Identifying and maximizing available tax deductions and credits to reduce tax liability.

  • Tax-saving strategies: Developing personalized tax strategies to minimize tax burden and optimize financial outcomes.

  • Retirement planning: Incorporating tax considerations into retirement planning strategies.


Business Taxes


  • Entity selection: Assisting with choosing the most suitable business structure based on tax implications.

  • Tax optimization: Implementing tax strategies to minimize the tax burden on businesses.

  • Payroll taxes: Ensuring compliance with payroll tax regulations and minimizing associated costs.


Estate Planning


  • Estate tax minimization: Developing strategies to reduce potential estate taxes.

  • Gift tax planning: Advising on gift tax implications and strategies.

  • Probate and trust administration: Providing guidance on probate and trust administration processes.


International Tax


  • Cross-border transactions: Assisting with the tax implications of cross-border transactions, such as investments and business operations.

  • Expatriate taxes: Advising on the tax implications of expatriate assignments and relocation.

  • Foreign income: Helping individuals and businesses navigate the complexities of foreign income taxation.


In essence, Bestar can save you time, money, and potential legal issues by ensuring that you are in compliance with tax laws, taking advantage of available tax benefits, and making informed financial decisions.










  • Hong Kong two-tier profits tax rates regime

  • Hong Kong two-tier profits tax regime

  • Two-Tiered Profit Tax Rates Regime In Hong Kong

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