China vs Hong Kong

Foreign-invested companies in China (commonly a WFOE or joint venture) register with the State Administration for Market Regulation (SAMR) and obtain a unified business license. Setup involves name approval, registered capital, a business scope and post-registration tax and bank steps.

You register a private company limited by shares with the Companies Registry and obtain the Business Registration Certificate from the Inland Revenue Department through the one-stop service. The company gets a Certificate of Incorporation and a business registration number; there is no minimum share capital.

China's banking is dominated by large state banks and is highly digital (Alipay and WeChat Pay are used almost everywhere). Foreigners can open accounts with a passport and often proof of local ties; a Chinese phone number is usually needed for mobile payments. The People's Bank of China is the central bank.

For a personal account you need a valid passport or HKID, proof of address and, for non-residents, income and banking references. A company account requires the Certificate of Incorporation, Business Registration Certificate, Articles of Association and identity/address checks on every director and beneficial owner. Hong Kong has no foreign-exchange controls, but non-residents should expect enhanced due diligence (rules tightened in 2026). The HKMA regulates banks and the Deposit Protection Scheme covers eligible deposits.

Foreign investment in China is governed by the Foreign Investment Law and a 'negative list' that limits or bars certain sectors; outside the list, foreign investors get national treatment. You set up a WFOE or joint venture, register with the authorities, and manage capital and profit repatriation under SAFE foreign-exchange rules; free-trade zones offer openings.

Hong Kong is one of the world's freest economies for foreign investment, promoted by InvestHK. There is no foreign-investment screening, no exchange controls, near-total foreign ownership, and a simple low-tax system. Capital and profits move completely freely, making it a leading base for regional holding and trading companies.

China's main taxes are Individual Income Tax (IIT), Corporate Income Tax and VAT, administered by the State Taxation Administration. Tax residents (generally 183+ days) are taxed on worldwide income, with a six-year rule easing this for some foreigners.

Hong Kong has a simple, low, territorial tax system: only Hong Kong-sourced income is taxed. Individuals pay salaries tax (with a standard-rate cap), there is no VAT, no capital gains tax and no tax on foreign income; the authority is the Inland Revenue Department.

Foreigners generally work in China on a Z visa, obtained after securing a job and a work-permit notification, then converted to a work-type residence permit after arrival. The employer and local foreigner-work authorities drive the process; there is no general work visa without an employer.

Professionals usually enter under the General Employment Policy (GEP) with a job offer sponsored by a Hong Kong employer; talent schemes such as the Top Talent Pass Scheme (TTPS) allow high earners and graduates of top universities to come without a prior job. You apply to the Immigration Department.

Chinese employment requires a written labour contract within a month of starting; local minimum wages apply, the standard week is 40 hours with capped overtime, and statutory paid annual leave runs 5-15 days by total service. Employers must pay the 'five insurances and one housing fund'; disputes go to labour arbitration before the courts.

Hong Kong employment under the Employment Ordinance sets a statutory minimum wage, paid annual leave rising with service, rest days, and — for those on a 'continuous contract' — sickness, holidays, and long-service or severance payments. MPF pension contributions are mandatory, and the Labour Tribunal resolves disputes.

Chinese trade clears through China Customs (GACC). You record-file as a consignee/consignor, then declare via the China International Trade Single Window. Goods are classified by HS code for import duty plus import VAT (usually 13%) and, for some products, consumption tax. Controlled goods need MOFCOM licences; advance rulings give certainty.

Hong Kong is a free port: there is no customs tariff or general import duty, and no VAT or GST. You lodge an import or export declaration with Customs and Excise (within 14 days, via the electronic trading services) and pay a small declaration charge. Excise duty applies only to liquor, tobacco, hydrocarbon oil and methyl alcohol; some goods need a licence.

Chinese trademarks are registered with the China National Intellectual Property Administration (CNIPA). China is strictly first-to-file, so registering early is essential. You search the register, file under the Chinese sub-class system, and after examination the mark publishes for a three-month opposition period. A Chinese trademark lasts 10 years and is renewable.

Hong Kong trademarks are registered with the Trade Marks Registry of the Intellectual Property Department (IPD). You search the register, file under Nice classes, and after examination the mark publishes for a three-month opposition period before registration. A Hong Kong trademark lasts 10 years and is renewable; China's Madrid membership does not extend to Hong Kong, so file separately.