In the chip field, the industrial chain has a high degree of international division of labor, often a lotHong Kong companyThey manufacture and sell chips using American technology, which means American companies license patents, manufacture them in Taiwan, and sell them to customers in China. According to the relevant provisions of the Hong Kong Inland Revenue Ordinance, if qualified, the patent fees paid by the Hong Kong company to the US company shall be withheld and paid by the Hong Kong profits tax, also known as departure tax.

The conditions mentioned here include: first,Hong Kong companyIs carried out in Hong Kong; Second, or the manufacturing activities are not in Hong Kong, but the operation of the Hong Kong company belongs to the onshore operation of Hong Kong, that is, it shall pay profits tax to the Hong Kong government every year, and the patent fee paid by the Hong Kong company shall be deducted as its expense before tax. As long as one of the above two conditions is satisfied, the patent fee paid by the Hong Kong company to the US company is subject to the withholding of departure tax.

Calculation of Departure Tax: The Hong Kong Inland Revenue Department willHong Kong companyThe fee paid to the software licensing unit is estimated to have30%The profit of theta, this is the profit of theta16.5%The tax rate of departure tax is calculated and the combined tax rate is equivalent4.95%In other words, multiply by the software royalty paid4.95%Let's figure it out.

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