Asia-Pacific
Asia Tax & Corporate Services
Gateway structuring, cross-border tax planning and corporate advisory for Western businesses entering Asia and Asian investors accessing Western markets — through Hong Kong and Shanghai.
Hong Kong
Hong Kong — Asia Gateway Structuring
Hong Kong remains the premier gateway for international businesses accessing Asian markets. With its territorial tax system, zero capital gains tax and extensive treaty network, we use Hong Kong entities as the cornerstone of Asia-Pacific structures for our European and Italian clients.
01
Hong Kong Company Formation & Management
Incorporation and ongoing management of Hong Kong Limited companies for international trading, holding and regional headquarters. We handle full statutory compliance, director services and company secretarial requirements.
- HK Private Limited Company incorporation
- Director and company secretary services
- Annual return and statutory compliance
- Bank account opening assistance
02
Hong Kong Tax Advisory & Profits Tax
Advisory on Hong Kong Profits Tax, offshore income claims and the two-tier tax regime. We assist European businesses to correctly structure their HK operations to benefit from the territorial tax system and minimise global tax leakage.
- Profits Tax filing and offshore income claims
- Two-tier tax rate planning (8.25% / 16.5%)
- Offshore claim justification and documentation
- Italy-HK tax treaty analysis
03
Asia-Pacific Holding & Regional HQ Structure
Design of multi-tier holding structures using Hong Kong as the Asia-Pacific apex, coordinating with mainland China (Shanghai), Italy and Luxembourg entities. We optimise dividend flows, royalties and capital gains across the group.
- HK HoldCo for APAC subsidiaries
- Dividend withholding tax optimisation
- Royalty and IP holding via Hong Kong
- Cross-border group treasury management
04
Cross-Border Italy & Hong Kong Structuring
Specialised advisory for Italian entrepreneurs and investors operating between Italy and Hong Kong. We navigate the intersection of Italian CFC rules, controlled foreign company legislation and HK territorial taxation to build efficient, compliant structures.
- Italian CFC rules analysis for HK entities
- Substance requirements and economic presence
- Inbound investment from HK into Italy
- IVAFE and foreign account reporting (Italy)
Shanghai
Shanghai & China Market Entry Advisory
Shanghai is China's financial capital and the primary entry point for foreign businesses accessing the Chinese market. We advise Western and Italian companies on China market entry structures, WFOE formation, transfer pricing and cross-border tax coordination with the Italian and European parent.
01
China Market Entry & WFOE Setup
End-to-end advisory for foreign companies establishing a presence in China through a Wholly Foreign-Owned Enterprise (WFOE) or Joint Venture in Shanghai. We guide clients through entity selection, registration, capital requirements and initial compliance.
- WFOE incorporation in Shanghai Free Trade Zone
- Joint Venture structuring and negotiation support
- Registered capital planning and injection
- Business scope and licence advisory
02
China Corporate Tax & Transfer Pricing
China Corporate Income Tax (CIT) advisory, annual filing support and transfer pricing documentation for intra-group transactions between the Chinese entity and European parent. We ensure compliance with China's BEPS-aligned transfer pricing rules and manage tax authority relations.
- CIT filing and annual reconciliation
- Transfer pricing documentation (master file / local file)
- Advance Pricing Agreements (APA) support
- Withholding tax on dividends, royalties and services
03
HK & China Combined Structure
Design of the classic HK holding + China operating company structure, widely used by Western groups to efficiently manage China profits, minimise withholding tax on dividends and maintain flexibility for future restructuring or exit.
- HK HoldCo + Shanghai WFOE two-tier structure
- Dividend repatriation and WHT planning
- Profit extraction strategies (management fees, royalties)
- Exit and liquidation planning
04
Italy & China Cross-Border Tax Coordination
Full coordination of Italy-China tax flows for Italian groups with Chinese operations: Italy-China tax treaty application, CFC analysis of Chinese entities under Italian law, VAT on cross-border services and individual tax advisory for Italian expats in China.
- Italy-China Tax Treaty application
- Italian CFC rules for China subsidiaries
- Expat individual tax advisory (Italy & China)
- VAT and customs on Italy-China trade flows
Ready to enter Asian markets?
Our Asia-Pacific specialists will design the optimal gateway structure for your business expansion and cross-border investments.
