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.