How Do Hong Kong Companies Repatriate Profits to the Mainland? A Comparison of Three Compliance Pathways for 2026: Dividends, Service Fees, and Royalties
Published: June 8, 2026

When a Hong Kong company makes a profit, it needs to transfer that money back to the mainland—this is an issue that many cross-border sellers eventually face.

Transferring funds directly from a Hong Kong account to a personal mainland account is certainly convenient, but doing so poses compliance risks in terms of both foreign exchange regulation and taxation.

Today, I’ll explain the three compliance paths in detail—choose the one that works best for you.

💡 If you're planning to repatriate profits from your Hong Kong company but aren't sure which route to take, feel free to add me on WeChat. qcygscszk or call 18676749275, text 【Remittance】 to receive a free route assessment and tax cost estimate.


01 Why Can't We “Transfer Directly”?”

Many people think: “Hong Kong is my own company—what’s wrong with transferring money back to my own account?”

The problem lies on two levels:

Level 1: Foreign Exchange Regulation
The mainland imposes clear restrictions on individual foreign exchange transactions (an annual foreign exchange conversion quota of the equivalent of $50,000 per person). Large sums transferred from overseas into personal accounts will trigger a bank’s report of large and suspicious transactions, and the State Administration of Foreign Exchange may require an explanation of the funds’ source.

Level 2: Taxation
A Hong Kong company is an overseas legal entity and is considered a separate taxpayer from you as an individual. If you receive funds from the company as “personal payments,” this may be deemed either a hidden dividend (requiring the payment of back personal income tax) or unreported overseas income.


02 Three Paths to Compliance

Path 1: Dividend Payouts

Applicable Scenarios: Shareholders of Hong Kong companies (who are also mainland residents) need to transfer the company’s profits to their personal accounts.

Process:

  1. Convene a board meeting to approve a dividend resolution
  2. Prepare the company's audit report (dividends must be based on audited financial statements)
  3. Hong Kong Banks Process Dividend Remittances
  4. When remitting funds to mainland China, file a report with the competent tax authority and complete the withholding procedure.

Tax Costs:

  • At the Hong Kong level: Since profits tax has already been paid, dividends are not subject to additional taxation.
  • Mainland China: Cross-border dividends are protected under the China-Hong Kong tax treaty, with applicable tax rates of 5% (for eligible cases) or 10% (for general cases).

Path 2: Service Fee

Applicable Scenarios: A Hong Kong company transfers funds to an affiliated company in mainland China (such as your mainland trading company) in the form of “service fees.”

Process:

  1. Service Agreement Signed Between a Hong Kong Company and a Mainland Company (Must Accurately Reflect the Nature of the Business)
  2. Hong Kong companies pay service fees in accordance with the agreement
  3. Mainland Companies Issuing Invoices and Reporting Revenue

Caveats:

  • Service fee pricing must be in line with fair market value (compliance requirements for transfer pricing in related-party transactions).
  • After receiving service fees, mainland companies pay taxes in accordance with standard corporate income tax rules.
  • “Shell service fees” with no actual service content carry the tax risk of being reclassified as dividends.

📌 If you already have a company in mainland China and would like to assess the feasibility of this service fee structure, please contact us.
Cell phone: 18676749275WeChat: qcygscszk

Path 3: Royalties

Applicable Scenarios: Mainland companies use intellectual property—such as trademarks, patents, and software—held by Hong Kong companies and pay royalties to those Hong Kong companies.

Process:

  1. Intellectual property held by a Hong Kong company (registered or licensed in Hong Kong)
  2. The two companies signed an intellectual property license agreement
  3. Mainland companies pay royalties in accordance with the agreement
  4. Completed verification and filing with the tax authority

Tax Costs:

  • Mainland Withholding Tax: 10% (reduced rate applicable under the China-Hong Kong Tax Treaty)
  • Hong Kong: Royalty income is subject to profits tax

03 Comparison of the Three Paths

comparison termDividendsservice feeroyalty
Requires real-world business supportunnecessaryneedRequired (Intellectual Property)
Tax Costs in Mainland China5%-10%Under Corporate Income Tax10% Withholding Tax
Compliance complexityLow (when there is actual business)
Common RisksThere are many approval proceduresInvestigation into Fraudulent Service FeesIntellectual Property Valuation

04 Foreign Exchange Compliance Requirements: Don’t Skip This Step

Regardless of the route taken, cross-border fund transfers exceeding a certain amount must undergo foreign exchange compliance registration:

  • ODI Filing (Outbound Direct Investment Filing): Mainland companies that have subsidiaries or equity-held companies in Hong Kong are required to file a report with the State Administration of Foreign Exchange.
  • Foreign Exchange Declaration for Trade in Services: When remitting service fees or royalty payments, the bank will require a contract and tax documentation.

If you skip this step, the bank will block the transfer.

📞 If you need a comprehensive profit repatriation solution (including ODI filing, contract drafting, and tax filing), please feel free to contact Qicaiying.
WeChat: qcygscszk Send [Refund] to receive one-on-one service.

Want to repatriate your Hong Kong company’s profits to the mainland in compliance with regulations? Text “Repatriation” to us, and we’ll provide a free analysis of the best approach and estimate the tax costs for you.

05 The Four Core Advantages of Qicaiying’s Hong Kong Company Services

🔹 1. A team of experts to guide you throughout the process

Our team of nearly 400 professionals, comprising senior Hong Kong licensed secretaries, certified public accountants, tax accountants and cross-border business consultants, handles tens of thousands of Hong Kong company registration and maintenance cases annually. We provide ”one-to-one” customized solutions from company structure design (e.g. Mainland-Hong Kong dual entity, VIE structure), name search, document preparation to government filing. We have 3 TCSP licensed secretaries and 1 self-owned Hong Kong CPA firm to ensure that every step of the process is legally compliant and to avoid risks from the source.

🔹 2. digitally empowered, smart and efficient

We have invested tens of millions of dollars to develop our own digital system ”E-Tron”, which realizes the standardization of the whole process and visualization of the progress of Hong Kong company registration, bank account opening, annual review, audit and tax filing, and so on. Customers can track the key nodes such as certificate issuance, bank interview, tax return submission, etc. in real time. The integration of AI intelligent analysis can quickly assess whether your business is suitable for applying for offshore exemption, whether you need to do transfer pricing, and assist in generating the optimal compliance program, so that complex matters are clear and transparent.

🔹 3. Eco-links, extra value

We connect over 500,000+ entrepreneurs with domestic and international associations (e.g. Shenzhen Cross-border E-commerce Association, Hong Kong Chinese General Chamber of Commerce), and regularly organize cross-border salons and seminars on finance and tax law. Registering a Hong Kong company through us is not just about getting a certificate - it is also about linking ecological resources such as green channel for bank account opening, cross-border payment, overseas warehouses, auditing and taxation, etc., which solves the problem of ”not knowing who to look for next after registering”, and creates secondary business opportunities.

🔹 4. Full-cycle accompaniment for worry-free sailing

Our services go beyond ”successful registration” to provide full life-cycle support for Hong Kong companies:

Previously: Free assessment of whether you need a Hong Kong company, recommending the optimal type of entity (Mainland company/Hong Kong company/Offshore company);

Midterm: Assist in completing Hong Kong company registration, bank account opening (HSBC / Overseas Chinese / Dah Sing / CBI and many other green channels), VAT / EIN application;

Late: Annual audits, audit tax returns, offshore exemption applications, CRS compliance, account freezes in case of emergencies, to become a long-term and robust partner for your overseas business. We automatically remind and handle all annual compliance matters on behalf of you on a nodal basis, and you just focus on your business.

Tags:
  • Hong Kong Company Compliance Guide
  • Hong Kong Company Tax Compliance
  • Hong Kong company