Who this is for
- Hong Kong companies receiving dividends, interest, royalties or service fees from the Chinese Mainland that want reduced rates under the Mainland–Hong Kong Arrangement
- Companies doing business with a jurisdiction that has a DTA with Hong Kong
- Companies incorporated outside Hong Kong but managed or controlled in Hong Kong (they must also complete the Appendix)
- Companies re-domiciled to Hong Kong
- Companies whose overseas customers or payers ask for proof of Hong Kong tax residency
What's included
- Understanding what the application is for, and confirming that the other jurisdiction has a DTA with Hong Kong that is in force
- Choosing the right form: IR1313A for the Chinese Mainland, IR1313B for other jurisdictions (current version 07/2025)
- Completing the application, including the nature and amount of the income, the beneficial owner, and details of business operations and staff
- For companies incorporated outside Hong Kong, putting together the "management and control" information the Appendix asks for (see Documents required below)
- Filing: we prepare the form and supporting documents for you to file online, by post or in person. If HKESC is your company secretary, we can discuss filing online for you through the Business Tax Portal (BTP); the company must first appoint us as its service agent on the BTP, and the arrangement is confirmed at consultation
- Helping prepare the documents to answer any IRD request for more information
What's not included
- Claiming the treaty benefit from the treaty partner's tax authority: holding a CoR does not by itself secure the benefit; the treaty partner makes the final decision
- Tax advice on treaty provisions, beneficial ownership or permanent establishment
- Applications for jurisdictions with no DTA with Hong Kong, or for purposes other than claiming DTA benefits (the IRD does not issue a CoR for these)
- Individual applications (IR1314A / IR1314B; ask us about these separately)
- Legal advice
Government / statutory fees
| Item | Amount (HKD) | Official source |
|---|---|---|
| CoR application | Free (HK$0) | IRD CoR FAQ, Q7 |
| For reference: a company carrying on business in Hong Kong needs a valid Business Registration Certificate (a business registration fee, not a CoR fee; commencing from 1 Apr 2026, levy included) | 1-year HK$2,350 / 3-year HK$6,170 | IRD fee table |
Documents required
This is a general document checklist; confirm the applicable items and secure handover arrangements at consultation. Please do not send identity or accounting records through the website form; your consultant will arrange a secure handover.
All company applicants:
- A completed IR1313A (Chinese Mainland) or IR1313B (other jurisdictions), signed by a director, the secretary or a manager
- A copy of the Certificate of Incorporation, plus any Certificate of Change of Name
- Re-domiciled companies: a copy of the certificate of re-domiciliation and a copy of the document evidencing deregistration from the place of incorporation
- The calendar year(s) claimed, the nature and amount of the income for which benefits are claimed, and the beneficial owner's name and address
- The Hong Kong business address, postal address and a Hong Kong contact person
- The nature of the business, where the headquarters and main branches are, and how many directors, senior managers and other staff have, or do not have, a fixed place of residence in Hong Kong
Since June 2023, companies incorporated in Hong Kong are generally not required to give full details of their establishment and business activities on the forms.
Companies incorporated outside Hong Kong (other than re-domiciled companies) must also complete the Appendix, which shows management and control in Hong Kong, including:
- Whether all income is passive or derived outside Hong Kong
- Where the business is carried on in each territory, what it does there, and the business address in each
- Staff numbers and duties at each establishment
- The Hong Kong business commencement date, and whether it matches the business registration and Companies Registry records
- The file reference of the Employer's Returns, or a list of Hong Kong staff and their pay
- Where management and control was exercised in each year claimed, and where central management and control was
- Each director's nationality, residential address, key responsibilities and where they performed their duties
- For each directors' meeting: the date, attendees, venue, matters discussed and resolutions passed
- How, where and by whom strategy, business direction, work plans, financing decisions, carrying out management policies and performance evaluation were handled
- The principal bankers in Hong Kong and the number of Hong Kong bank accounts
- The nature of the permanent establishment in Hong Kong, and the value of fixed assets and the cash at bank
Mainland dividend claims: if the claim falls under Article 3 or 4 of STA Circular 2018 No. 9, complete Part 2 of the IR1313A Appendix.
Japan DTA claims: complete the IR1313B Appendix.
Process and timeline
Case timing is confirmed during consultation and depends on documents, authorities and third parties. No completion or approval time is guaranteed; statutory deadlines require separate checking.
- Consultation: we confirm the purpose, the income type and the other jurisdiction, then send a quote
- You send company documents; we draft the form (and Appendix) and organise the supporting documents
- A director reviews and signs
- Filing: you file it yourself online, by post or in person; if HKESC is your company secretary, we can discuss filing online via the BTP for you
- IRD processing: the IRD's target is to issue the CoR, or a letter asking for more information or rejecting the application, within 21 working days of receiving a properly completed application
- If the IRD asks for more information, we help prepare the reply; once approved, the digital CoR is downloaded or the paper certificate collected
Timing: depends on how complete your information is; we confirm it at the consultation. The 21 working days is the IRD's official performance target; requests for more information extend it.
Annual obligations and statutory deadlines
- A CoR is not a statutory annual filing. You apply when you need one.
- Chinese Mainland: a CoR issued for a calendar year generally proves Hong Kong residency for that year and the two following calendar years, unless your circumstances change and you no longer meet the conditions.
- Other jurisdictions: generally only one CoR is issued per DTA per year. A single application can cover up to three calendar years.
- Digital CoR: since 10 November 2025, successful applicants for Mainland treaty benefits receive a digital CoR (PDF) in their BTP account inbox. Paper certificates are still posted for other jurisdictions.
- The company still files its Profits Tax Return, Employer's Return and Annual Return on time each year. The Appendix to IR1313A and IR1313B also asks for details such as the Employer's Return file reference.
FAQ
Which companies can apply for a CoR?
In general, companies incorporated in Hong Kong, companies incorporated outside Hong Kong but managed or controlled in Hong Kong, and re-domiciled companies can apply. Whether a company counts as a "Hong Kong resident" for a particular DTA depends on that DTA's articles and protocol.
What is the difference between IR1313A and IR1313B?
IR1313A is for benefits under the Mainland–Hong Kong Arrangement. IR1313B is for every other jurisdiction with a DTA with Hong Kong. Individuals use IR1314A / IR1314B.
Is there an application fee?
No. The IRD charges no fee.
How long does it take?
The IRD aims to issue the CoR, or tell you it needs more information or cannot accept the application, within 21 working days of receiving a properly completed application.
Can I apply if the other country has no DTA with Hong Kong?
No. The IRD only issues a CoR to a Hong Kong resident claiming DTA benefits, and only once the DTA is in force. It will not issue one for other purposes, such as opening a bank account.
Will a CoR always get me the lower tax rate?
No. The treaty partner decides whether to grant the benefit. If you believe it has wrongly refused, the Hong Kong competent authority may consider taking it up under the DTA's mutual agreement procedure.
My company is incorporated in the BVI or elsewhere. Can it get a Hong Kong CoR?
Yes, if it is managed or controlled in Hong Kong. You must complete the Appendix with full details of the directors, board meetings, strategic decisions, staff, bank accounts and permanent establishment in Hong Kong to show that management and control is here.
For Mainland claims, do I apply every year?
Usually not. A CoR for one calendar year generally covers that year and the next two, unless the company's circumstances change and it no longer qualifies.
Can HKESC file the application for us?
We prepare the form and supporting documents, and you normally file the application yourself online, by post or in person. If HKESC is your company secretary, we can discuss filing it online for you: the company first appoints us on the BTP as its service agent for CoR matters, and the actual arrangements, eligible channel and company authorisation must be confirmed at consultation.