Background
- Mr. A owns intellectual property or technology that can be licensed to other company for commercial use.
- Mr. A setup Hong Kong company H Ltd, and register H Ltd as the owner of the intellectual property (IP);
- H Ltd licensed use of the IP to a USA company for production use;
- H Ltd received royalty income base on the use of the IP in USA.
- The royalty income received by H Ltd is not subject to Hong Kong profits tax;
- Such income will be taxable if the use of IP is located in Hong Kong.


