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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.

There is no separate application or exemption certificate. An offshore claim is simply a position taken in your return that certain profits have a source outside Hong Kong.

Steps

  1. Work out, transaction by transaction, where the profit-producing operations took place (for trading: where contracts of purchase and sale were made, goods sourced and sold, who negotiated).
  2. Exclude the offshore profits from the tax computation. Apportion expenses between offshore and onshore income.
  3. Report the excluded offshore profits in the profits tax return (the return has specific items for this).
  4. Submit the schedules the IRD asks for, such as offshore profits and apportionment of related expenses.
  5. Keep the documents: contracts, emails, shipping and payment records, who travelled where, board minutes.

What the IRD says. Taxpayers should be ready to prove in their returns, with supporting documentary evidence, that a profit was derived outside Hong Kong.

Limits. An offshore claim does not remove tax on Hong Kong-sourced income, and it does not override the FSIE regime for foreign-sourced passive income of multinational group members. Claims for interest and services income tend to attract particular attention.

If the IRD rejects the claim, you can object within one month of the assessment notice.

  • Inland Revenue Ordinance (Cap. 112), s.14
  • Inland Revenue Ordinance (Cap. 112), s.51(4)

Sources

Applies to YA 2025/26 · 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.

    How does an offshore profits claim work in Hong Kong? | OCTIS