November 10, 2025—This is a watershed moment for those who are currently applying for or planning to apply for a Certificate of Residence (CoR) in Hong Kong.

Starting today, all CoR applications for mainland China use will be issued electronically. However, even more critical than this ”digitization” is another, often-overlooked shift: the focus of the review has shifted from ”formal compliance” to ”substantive review.” Simply put—whereas in the past an application might have been approved simply by having ”all required documents,” the tax authorities now examine your ”actual life trajectory” and ”evidence of actual business operations.”

If you’re still using the 2024 approach to prepare for your 2026 application, we recommend reading this article word for word.

I. After November 2025, digitization will bring about three major changes

Change 1: All permits for use within the mainland are now issued electronically; paper versions are no longer issued.

Once approved, the CoR will be sent in encrypted electronic form to the applicant’s ”TaxEasy” account inbox. Mainland tax authorities can verify its authenticity online. The advantages are faster processing and no need to visit the tax office to pick it up; however, applicants must have a ”TaxEasy” account set up and be actively using it—a preparatory step that many people tend to overlook.

Change 2: All versions of the form have been updated to the 07/2025 version.

Both the IR1313A application form for mainland-based companies and the IR1314A form for individuals have been updated to the 07/2025 version. Applications submitted using older versions of the forms will be returned. This is an area where mistakes are easily made—many people may still be using older versions downloaded from the internet.

Change 3: Electronic certificates must be downloaded within the specified time limit

Once approved, you must download the document from the ”TaxEasy” system within the specified time limit. If you fail to download it by the deadline, the certificate may expire, and you will need to reapply. We recommend that you download and back up the document as soon as possible after receiving the approval notification.

II. The Era of Substantive Review: The Tax Authority Is Examining You from ”Four Dimensions”

In the past, the process for applying for a CoR was simply ”fill out the form and submit the documents”; as long as the documents were complete in form, the approval rate was relatively high. Now, however, the tax authorities are increasingly focusing on a deeper issue: Is Hong Kong truly your center of life and business?

For individual applicants, the tax authority considers four factors:

① Permanent residence:Do you own or rent a permanent residence in Hong Kong on a long-term basis? If so, can you provide consecutive utility bills and a lease agreement?

② Key Centers of Interest:Is Hong Kong your primary source of income? Are your core social ties—such as family, children, healthcare, and bank accounts—based in Hong Kong?

③ Habitual residence:How many days did you actually stay in Hong Kong during a tax year? Does this constitute ”habitual residence”?

④ Completeness of entry and exit records:Did a single departure from Hong Kong exceed 180 days? If so, are there any supporting documents, such as a company assignment letter, to explain the situation?

For corporate applicants, the tax authority will review:

① Areas under management control:Are the directors based in Hong Kong? Are board meetings held in Hong Kong? Are major business decisions made in Hong Kong?

② Substance of the Business:Do you have a local office, local employees, and MPF contribution records?

③ Financial Substance:Have you opened a corporate bank account in Hong Kong? Have you filed and paid profits tax in Hong Kong?

④ Business Activities:Are there genuine business contracts, invoices, and shipping documents that can prove the business transactions actually took place in Hong Kong?

3. The Key Challenge for ”Dual Tax Residents”: The Gabi Rule

For many individuals living across borders, the real challenge with a CoR application lies in the fact that you may be considered a tax resident of both mainland China and Hong Kong at the same time. In such cases, the tax authorities of both jurisdictions will apply the ”tie-breaker rules” to determine which jurisdiction you ultimately belong to:

👉 Top Priority: Permanent residence. If you have residences in both places, consider which one is more stable and long-term. Recommendation: Purchase a property in Hong Kong or rent long-term there, and maintain a complete record of your residency.

👉 Second Priority: Center of Vital Interests. Determine which side your financial relationships (sources of income, asset allocation) and personal relationships (family, children’s education) are more closely tied to. Recommendation: Centralize your primary bank accounts, major investment activities, and family life in Hong Kong.

👉 Third criterion: Habitual residence. Which place is your ”usual place of residence”? Try not to stay away from Hong Kong for more than 180 days at a time.

👉 Final Ruling: If the above rules still fail to resolve the issue, the tax authorities of both jurisdictions will resolve it through consultation—this is the outcome we hope to avoid most, as it means your tax status will be determined by others on your behalf.

[Free Consultation]

Cell phone: 18676749275 ｜ WeChat: qcygscszk

Qicaiying’s professional consultants provide one-on-one guidance to help you assess the feasibility of your application and organize the required documents.

IV. Recommended Application Timeline: Don’t Wait Until the Last Month

Standard processing time: approximately 21 business days. Complex cases or cases requiring additional documentation: processing time may be extended to 2–3 months.

We recommend working backward from the following milestones to estimate your preparation time:

📅 Date by which the CoR is required (e.g., tax filing deadline, subsidy application deadline) → Start preparing documents two months in advance → Submit the application one month in advance → Allow time for any requested additional documentation.

Waiting until ”CoR is needed” to start the application process—it’s too late for 90%.

V. Qi Cai Ying: Helps You Establish the ”Chain of Evidence” for Your CoR Application Right from the Start

In the era of ”substantive examination,” applying for a Certificate of Registration (CoR) is no longer a matter of simply ”filling out a form once”; rather, it is a systematic process that must be planned from the very first day of company registration. What Qi Cai Ying offers to cross-border professionals is precisely this end-to-end, closed-loop service:

✔️ Hong Kong Company Registration: We take business substance into account right from the start of the structural design to ensure a solid foundation for compliance from the moment of registration;

✔️ Bank account opening + financial and tax compliance: corporate bank accounts, audit reports, and profit tax returns—these are all key pieces of evidence for the substantive review;

✔️ Comprehensive CoR application guidance: form selection, document organization, evidence chain construction, and submission follow-up—you focus on your business; leave compliance to us.

After November 2025, the policy changed. But those who plan ahead never have to worry.

[Free Consultation]

Cell phone: 18676749275 ｜ WeChat: qcygscszk

Qicaiying’s professional consultants provide one-on-one guidance to help you assess the feasibility of your application and organize the required documents.