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Posted Thu, 11 Jan 2024 20:31:13 GMT by
I own a unlimited company registered and running in Hong Kong for the year 2022/23. More than 95% of the operation and decision making is made by my colleagues in Hong Kong. And the unlimited company had paid profit tax to the Hong Kong Government for the year 2022/23 already. As I am a resident in UK now, may I know if the unlimited company needs to pay profit tax in UK? Thank you.
Posted Wed, 17 Jan 2024 08:37:19 GMT by HMRC Admin 20 Response
Hi jeffexhibit Chan,
No.
Article 7(1) of the UK / Hong Kong tax treaty advises that the profits of an enterprise of Hong Kong shall be taxable only in 
Hong Kong, unless the enterprise carries on business in the UK, through a permanent establishment situated therein.  
If the enterprise carries on business in the UK, the profits of the enterprise may be taxed in the UK, but only so much of them as is attributable to the UK.
UK/HONG KONG DOUBLE TAXATION AGREEMENT AND PROTOCOL.
Thank you.

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