HK trading intermediaries are legitimate and common for mainland groups, but require real documentation flow (contracts, invoices matching goods), transfer pricing support, and clean banking history — paper-only flow-through accounts get frozen.
Making it work: (1) Real function — procurement, trading, or service hub with documented pricing logic (why the margin sits in HK). (2) Transfer pricing: HK margin should match functions performed; mainland tax authority checks related-party pricing; keep an TP memo. (3) Banking: provide trade documents proactively; discrepancies between declared and actual flows are the #1 freeze cause. (4) Tax: HK profits tax on the intermediary margin (8.25%/16.5%); mainland side may challenge if functions don't justify profit. (5) Payment licensing: pure payment collection for third parties (not own trades) can constitute licensed activity — do not provide 'collection services' for unrelated merchants. Structure it as your group's own trading entity with substance.
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