A Hong Kong seller company: what records and tax facts still matter?
Incorporation alone does not establish that trading profit is offshore or tax-free.
Source checked:
Timing: IRD guidance checked 24 October 2026; this is not a new incorporation deadline.
Does this affect my business?
International sellers using or considering a Hong Kong company for marketplace or direct-store sales.
What do we know?
Start with the business, not the incorporation certificate. IRD’s territorial-source guidance examines the operations that produce the trading profits and where they occur. An overseas customer or money paid into a Hong Kong bank account is not, by itself, a complete source analysis.
Do not confuse trading profit with FSIE. The foreign-sourced income exemption regime addresses specified foreign-sourced income received in Hong Kong by relevant multinational-enterprise entities, with defined conditions. It is not an automatic exemption for every Hong Kong company’s e-commerce revenue. Other countries’ obligations require their own factual review.
Make the records usable. IRD requires sufficient business records to establish assessable profits and retention for at least seven years. For an online seller, start by reconciling orders, refunds, marketplace deductions, supplier invoices, stock movements and bank settlements. Ask the current accountant which supporting documents are missing; a commercial receipt is not automatically evidence that every expense is deductible.
Start with these checks. You may already have what you need.
| Question | What to check | Useful next step |
|---|---|---|
| Where is the work producing profit done? | Contracts, purchasing, selling and the people making those decisions. | Prepare a factual operating description for your adviser. |
| Which income and tax rules are being discussed? | Trading profit versus specified foreign-sourced income; other operating countries. | Ask for the reasoning behind any exemption claim. |
| Can I reconcile the actual transactions? | Orders, costs, inventory and bank settlements. | Fill gaps in the existing records before buying a new entity structure. |
You can use this checklist yourself or with your existing adviser. To ask OCW, describe the missing facts in your own words. This article is available for reading and manual follow-up; it does not enable an automatic answer for this topic.
Sources and review date
Official source — Hong Kong IRD — Territorial source principle
Official source — Hong Kong IRD — FSIE frequently asked questions
Official source — Hong Kong IRD — Business record keeping
Sources checked on 24 October 2026. The explanation distinguishes current requirements, platform access and practical checks; the check date is not a new effective date.
Source checked:
Reading version
hong-kong-seller-records / ocw-hong-kong-seller-records-20261024-v1
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