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ECONOMIC SUBSTANCE REGULATIONS
BACKGROUND
The Council of the European Union (EU) adopted a resolution on a Code of Conduct for business taxation, the aim of which was counteracting the effects of zero tax and preferential tax regimes around the world. On 3 December 2017, the EU proposed their list of “non-cooperative” taxation jurisdictions, popularly referred to as the “EU Black List” which will be reviewed at least once a year.
LEGISLATION
Following assessment by the Code of Conduct Group (Group), each non-EU relevant jurisdiction was required to address the Group’s concerns about “economic substance”. Some of the governments, says, Bermuda, the British Virgin Islands and the Cayman Islands, have passed legislation that will require certain legal entities carrying on “relevant activities” to have “economic substance” in the jurisdiction, which includes having adequate employees and premises for carrying out the management as well as certain filing requirements. No action is required if an entity is not carrying on a relevant activity.
HOLDING COMPANY
No matter it is a listed company or a private company, a “pure equity holding entity” which only holds equity participations in other entities and only earns dividends and capital gains, will be subject to reduced requirements in meeting the economic substance requirements, which may be satisfied by engaging its registered agent and maintaining a registered office in the jurisdiction. Exact requirements are still in the course of further amendment.
TAX RESIDENCE
An entity that carries on a relevant activity during a reporting period will not need to meet the economic substance requirements during that reporting period if it is resident for tax purposes in another jurisdiction which is not on the EU Black List for the entirety of that reporting period. Entities will be required to report where they are tax resident and to furnish proof of tax residence.
Entities which seek to take advantage of another jurisdiction’s zero or low tax regime, while carrying on their business substantially in another jurisdiction will be required to:
a) ensure that the substance of the relevant activity is carried on within that jurisdiction, or
b) discontinue the activity, or modify it so it no longer falls within the scope of a relevant activity, or
c) demonstrate a tax residence in another jurisdiction which is not on the EU Black List.
The specific provisions on the economic substantive regulations are still being drafted and are subject to further publication by the respective jurisdictions.
NORCOLA COMPANY LIMITED, a member of BM Intelligence Group, provides our clients with a comprehensive range of corporate secretarial services and solutions to fulfil the Economic Substance Requirements. For more information, please contact:-
Name : Ms. Eva Lam
Tel : (852) 2159 5003 / (852) 5175 2662
Email : info@norcola.com.hk
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Hong Kong real-estate project and house for lease
Infiniti Pacific Properties Limited is an international real-estate service provider. We provide a full range of real estate services, spanning from corporate occupier services to strategic consultancy, project appraisal, valuation, feasibility studies and market research, property management, facilities and asset management and transactional services. Following are some of our promoting projects. |
| Duplex - The Royal Court (Mid-Level) |
The Oakhill - Wan Chai |
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High Floor, Duplex, The Royal Court, 3 Kennedy Road, ML
- SA: 2,217 sqft
- GA: 2,800 sqft
- 3 large beds (1 ensuite), walk-in closet, 2 baths, large kitchen, large balcony with beautiful central city & harbor view
- For sale: $83.8M w/lease
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High Floor A & B (two units on one floor), The Oakhill, No. 28 Wood Road, Wan Chai
Each unit size: SA: 1,185sqft, GA: 1,551 sqft
- 3 beds (1 ensuite), 2 baths, maid’s room (w/ bath)
- 2 balconies with race course view & city harbor view
- Prime Prime location in Wan Chai close to MTR
- Good for investment, Best school district
- 50 A&B Both $70M w/Lease (sale by company)
- Each unit for $35M w/Lease
- Car park space $2.2M each
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| Po Yue Yuk Building - Mid-Level |
The Oakhill - Wan Chai |
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Mid Floor, Po Yue Yuk Building, 61 Robinson Road, ML
- SA: 1,114 sqft
- GA: 1,463 sqft
- Two Bedrooms (1 large ensuite), study area, 2½ baths, Maid room
- Balcony with open view
- One unit per flat; private lift to your own unit
- For sale HK$20.8M
- For lease HK$55K
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Special Unit, The Oakhill, No.28 Wood Road, Wanchai
- SA: 644 sqft
- GA: 877 sqft
- 2 beds (1 ensuite), 2 baths, maid’s room
- Private, huge with split level terrace SA: 1,347 sqft with open view (Happy Valley & Wanchai view)
- Prime and convenience location, close to MTR
- For sale w/lease: $ 18.8M
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| Clear Water Bay - Beautiful House by Beach |
Pak Fai Mansion - Macdonnell Road, Mid-Level |
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42 Sheung Sze Wan, Lot No.655 in DD230 Clear Water Bay
- Saleable area 2,100 sqft
- 3-storey village house with large front terrace facing seaview
- Nearby beachside, full seaview
- 4 beds (1 ensuite) with car parking space
- For Sale: $29.9M w/lease
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Unique JOINT Units
Pak Fai Mansion, Unit C & D, No. 72 Macdonnell Road, Mid-Level
- Size: SA: 2,579 sqft, Unit C & D
- 3 beds (1 large master ensuite), 1 study room, 3.5 baths
- 1 large family room with open fully equipped open kitchen
- 1 large living & dining area
- Balcony with open city view with greenery
- For sale: HK$ 49.8M
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| Jade Garden - Robinson Road (MLW) |
Cavendish Heights - Perkins Road, MLE |
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Mid Floor, Jade Garden, 105 Robinson Road, MLW
- SA: 1,304 sqft
- GA: 1,628 sqft
- 3 beds (1 ensuite)
- Large balcony w/greenery view
- Modern kitchen with fully fitted kitchen appliance
- Convenience location to Central, SoHo Area
- For sale: $28.8M w/ 1car park space
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High Floor, Cavendish Heights, 33 Perkins Road, MLE
- Size: N 1,510’ / G 1,819’
- 3 beds (1 ensuite), 2 baths, large modern kitchen, maid room
- Large balcony with beautiful greenery / seaview
- Newly renovated with fully equipped kitchen & upgraded baths
- 1 car park space
- For lease: HK$69K
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| North Point Industrial Building - North Point |
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- Gross: 8,750’ Second floor
- Close to MTR, prime location
- Suitable for designer’s show flat, printing / publishing, IT software companies, office / warehouse
- For lease: HK$18 per sqft
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For details, please contact Ms. Monita Luk at (852) 9333 3124 / (852) 6982 3998 / mluk@infinitip.com |
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Tailor-made corporate training – Directors' Training
BMI Professional Training Centre Limited strives to provide professional, high quality and reliable training courses. Apart from regular courses with fixed schedule and content, we also tailor-made corporate training courses that fulfill unique demands of corporate clients.
Our popular tailor-made directors' training courses covers a comprehensive range of topics related to listing rules, including director responsibility, code on corporate governance, responsibilities of the Board of listed companies and overview of Hong Kong Listing Rules etc. Our courses are recognized by HKEX.
Interested parties or organizations may visit our website: http://www.bmiptc.com
Or contact Ms. Chan at (852) 3970 9230 / schan@bmintelligence.com |
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Economic Conference Room Rental Package
BMI Professional Training Centre is pleased to offer the rental of conference room at a convenience location in Wan Chai. it is suitable for organizing events, such as seminars workshops, training, press conferences.
MORE INFORMATION
Should you have any enquires, please feel free to contact us on (852) 3970 9235 or by registration@bmiptc.com
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