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Jordans Trust Company receives many enquiries for both Hong Kong and Singapore from businesses expanding into Asia. But what are the key characteristics of each, and which has the edge?
With superb financial services infrastructure both Singapore and Hong Kong are well respected international financial centres. They are respectively the first and second ranked countries in the World Bank's ranking of Ease of Doing Business 2013 and Trading Across Borders 2013.
The headline corporate tax rates are 16.5% in Hong Kong and 17% in Singapore. Both operate a territorial taxation system which means only profits arising from Hong Kong or Singapore source activities are taxed. Non-source activities are tax free.
Singaporean companies are not subject to withholding tax on outbound dividend payments. Hong Kong does not impose withholding taxes on outbound dividends, interest or any other income, whether paid to residents or non-residents (except for certain royalty payments).
Hong Kong does not impose sales tax whereas Singapore has a Goods and Service Tax (VAT) at a rate of 7%. Neither Hong Kong nor Singapore imposes estate duties.
Both Singapore and Hong Kong have extensive networks of double taxation treaties with key markets including the UK, other western European countries and China. Treaties with other BRIC countries, such as Russia are under negotiation. If Chinese investments are of consideration, withholding tax on dividends from China can be reduced to 5% under both countries respective tax treaties however Hong Kong is often preferred due to its proximity to the mainland and its status as a Special Administrative Region (SAR) of China. Singapore tends to be more frequently used for investment into South East Asia due to its membership of the Association of South East Asian Nations, but both can be effectively be used for investment across Asia.
Both Singapore and Hong Kong should receive detailed consideration if you are thinking about investing into Asia, either for direct trade or via an efficient holding structure.
Author
Stefano Iacono LLB (Hons) Law and French
Consultant - Corporate and Trust Planning Team
Jordans Trust Company Limited