CEPA Tax Structuring

Leveraging a Unique Advantage for China Market Access

The Closer Economic Partnership Arrangement, commonly known as CEPA, is a landmark free-trade agreement between Mainland China and Hong Kong. It provides qualifying Hong Kong businesses with a significant competitive advantage, offering preferential access and relaxed requirements for a wide range of goods and services entering the vast Chinese market. For businesses in qualifying sectors, leveraging CEPA can be a powerful strategy for accelerating market entry, reducing operational costs, and enhancing profitability.

However, benefiting from the arrangement is not automatic; it requires careful planning and structuring to ensure that a business meets all the specific eligibility criteria. Zetland Fiduciary Group provides expert advisory and implementation support for businesses looking to structure their operations to take advantage of the CEPA framework. We help you to design and implement corporate structures, operational workflows, and documentary evidence trails that are fully aligned with the detailed CEPA requirements.

Our approach is practical, ensuring that the structure is not only compliant for CEPA qualification purposes but is also efficient and workable for your day-to-day business execution. We coordinate closely with your tax counsel and manage the crucial interfaces between your accounting and tax functions to support your initial application and to ensure your business maintains its eligibility and ongoing compliance with the arrangement's rules.

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A Practical Approach to CEPA Qualification and Compliance

Our service is designed to provide end-to-end support for your CEPA structuring needs, with close coordination between our Hong Kong and Shanghai teams. The process begins with a detailed eligibility assessment, where we analyse your business operations against the specific CEPA requirements for your industry and provide a clear overview of the necessary documentation. We then work with you on your operating structure and substance planning. This is a critical phase where we help you to design or refine your Hong Kong presence and operational model to ensure it demonstrates the required level of substantive business activity to qualify as a Hong Kong company under the CEPA rules.

This often involves advising on office setup, staffing levels, and the nature of the activities conducted in Hong Kong. We provide expert coordination on all the tax and regulatory aspects of the structure, ensuring that your accounting processes and financial records are perfectly aligned to support your CEPA-related filings and declarations. Once your structure is in place, we provide support for ongoing monitoring and evidence retention, helping you to maintain a comprehensive and auditable record of your compliance with the CEPA rules.

The outcome of our engagement is a practical and defensible corporate structure that allows you to make effective use of the CEPA arrangements where appropriate, providing a valuable strategic advantage for your business in Mainland China.