Tax residence certificate & TIN [ 中文 ]

Tax Residence Certificate (TRC)

• China 
• Hong Kong
• India
• Singapore
• the United Kingdom

Tax Identification Number (TIN)

• China
• Hong Kong (including reasons not having a TIN)
• India
• Singapore
• the United Kingdom
• OECD TIN database

 

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Tax Residence Certifcate Application Rules in China

• State Administration of Taxation - Public Notice [2019] 17 [Chinese version]
• Tax residence certificate application form [read]
• Tax residence certificate [read]

 

Tax Residence Certificate Application in Hong Kong

• Certificate of Resident Status [read]
• Application forms

DTA Partner	Form
	Company / Partnership / Trust / Body of Persons	Individual
The Mainland of China	IR1313A (03/2018)	IR1314A (03/2018)
Other Jurisdictions	IR1313B (03/2018)	IR1314B (03/2018)

 

HK-based BVI Company not having a TIN and the reasons for it

 

A non-Hong Kong company (i.e. a BVI Company) may be considered to be resident in Hong Kong because it has no directors, management staff, and employees resident in the BVI. Admittedly, that BVI company is managed in Hong Kong as the directors are resident in Hong Kong.

However, it does not follow that the BVI company, being resident in HK, is carrying on trade or business in Hong Kong.

Hong Kong tax rules (section 14 of the Inland Revenue Ordinance) provide that a person (including HK and Non-HK entity) is not taxed by reason of its resident status. Instead, that person is taxed by the business activities it performed in Hong Kong.

As the BVI company is not carrying on any business in Hong Kong, the IRD will not issue a TIN to it.

 

 

Tax Residence Certificate Application in India

• Certificate of Tax Residence - Section 90(4) of the Income Tax Act [read]
• Section 90(4) - Form 10F [for use by non-residents] [read] 

 

Tax Residence Certificate Application in Singapore

• Determining Tax Residence [read]
• Certificate of Resident / Certified Tax Reclaim Form [read]

 

Tax Residence in the United Kingdom

• Determing Tax Residence (statutory residence test) [read] 
• Certificate of Tax Residence [read]
• Evidencing your UK tax residence [read] 

 

 

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Tax Identification Number (TIN) - China

 

See the information for TIN in China: [Read-China]

 

Tax Identification Number (TIN) - Hong Kong

 

The IRD uses Hong Kong Identity (HKID) numbers and business registration numbers for CRS reporting purposes.

Individuals: Hong Kong Identity Card (HKID) number is the TIN, which takes the following format: - 

 

Companies or Entities: Business Registration (BR) number, issued by the Inland Revenue Department under the Business Registration Ordinance (Cap 310)

See the source of the above information from the OECD website : [Read-HK]

 

Case1: TIN plays a dual role in Hong Kong

The TIN of an individual taxpayer has a second use by the IRD for domestic tax administration purposes. The TIN of an individual taxpayer takes the format of a 10-digit numeric string. The TIN in its domestic context is used as a login ID or credential for an individual taxpayer to gain access to the IRD's Individual Tax Portal (ITP).

 

Case2: HK-based BVI Company not having a TIN and the reasons for it

A non-Hong Kong company (i.e. a BVI Company) may be considered to be resident in Hong Kong because it has no directors and employees resident in the BVI. Admittedly, that BVI company is managed in Hong Kong as the directors are resident in Hong Kong.

However, it does not follow that the BVI company, being resident in HK, is carrying on trade or business in Hong Kong.

Hong Kong tax rules (section 14 of the Inland Revenue Ordinance) provide that a person (including HK and Non-HK entity) is not taxed by reason of its resident status. Instead, that person is taxed by the business activities it performed in Hong Kong.

As the BVI company is not carrying on any business in Hong Kong, the IRD will not issue a TIN to it.

 

Tax Indentification Number (TIN) - India

• Permanent Account Number [PAN]

 

Tax Indentification Number (TIN) - Singapore

• TIN - [read]

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Tax Indentification Number (TIN) - United Kingdom

• TIN (UTR, Unique taxpayer reference) - [read]

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Tax Indentification Number (TIN) - Other jurisdictions

• OECD TIN database [read]

 

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