How do I get a Hong Kong certificate of resident status for a tax treaty?
Apply to the IRD for a Certificate of Resident Status (CoR) through the Business Tax Portal, Individual Tax Portal or Tax Representative Portal. There is no fee, and the IRD's target is 21 working days. It is issued only to Hong Kong residents and only for countries whose treaty with Hong Kong is already effective.
A CoR is the document the Hong Kong competent authority gives to a Hong Kong resident who needs to prove resident status to claim benefits under a comprehensive double taxation agreement (DTA).
Who is a Hong Kong resident entity:
- A company, partnership or trust incorporated or constituted in Hong Kong.
- One incorporated or constituted outside Hong Kong but managed or controlled in Hong Kong.
- A re-domiciled company, once re-domiciliation is complete.
How to apply. The applicant or its service agent (company secretary or tax representative) submits the application via the Business Tax Portal, Individual Tax Portal or Tax Representative Portal. The IRD's FAQ says no fee is payable.
Timing. The IRD aims to issue the CoR, or reply with questions or a refusal, within 21 working days of a properly completed application. The certificate is usually sent electronically to the applicant's portal inbox.
Limits
- A CoR is not issued for use in a country with which the treaty is not yet effective.
- It is not proof that a particular treaty rate applies; the foreign tax authority decides that.
- It does not cover Hong Kong's tax treatment of your income.
Allow extra time if you need it for a foreign filing deadline.
Sources
Applies to As at 2026-10-29 · Last reviewed 29 October 2026
General information for business owners, not legal, tax or professional advice. Rules change, so check the sources or ask a licensed professional before you act.
Related questions
- Does a Hong Kong company pay tax on profits earned overseas?Generally no. Profits sourced outside Hong Kong are outside the profits tax charge, even if the company is incorporated here. The exceptions are certain foreign-sourced passive income received in Hong Kong by members of multinational groups under the FSIE regime, and any profits the IRD finds are actually sourced in Hong Kong.
- How does an offshore profits claim work in Hong Kong?An offshore claim says that some or all profits did not arise in or derive from Hong Kong, so they are outside profits tax. You exclude them in the tax computation and report them in the return. The IRD can then make enquiries, and it is up to the taxpayer to prove the source with documents.
- Does it matter where a Hong Kong company's directors make decisions when claiming offshore profits?It is a factor but usually not the deciding one. The IRD and the courts look first at the operations that actually earned the profit and where they took place. The place where day-to-day investment or business decisions are taken is only one factor, so directors abroad do not by themselves make profits offshore.
- What is Hong Kong's FSIE regime for foreign-sourced income?The FSIE regime can tax four types of foreign-sourced passive income when received in Hong Kong by members of multinational groups: dividends, interest, disposal gains and IP income. It started on 1 January 2023, with disposal gains on non-equity assets added from 1 January 2024. Exceptions such as economic substance can keep the income exempt.
- What economic substance do I need to keep foreign dividends or interest exempt under the FSIE rules?A multinational group entity must show adequate substance in Hong Kong in the year the income accrues. A pure equity-holding entity needs adequate human resources and premises and must meet filing duties. Other entities need an adequate number of qualified employees and operating expenditure. The IRD sets no minimum numbers.