Hong Kong tax - Offshore claims - Tax Planning for Manufacturing Profits

A Hong Kong manufacturing business enters into a processing or assembly arrangement with a Mainland entity. The Hong Kong manufacturing business will provide the raw materials, technical know-how, management, training and supervision provided by the HK entity. It may be possible to follow the decision of court cases to be entitled apportionment of profit to be exempt from being taxable in Hong Kong. A 50:50 apportionment can be made.