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.

If you’re in the cross-border e-commerce business, you’ve likely already registered a Hong Kong company and use a Hong Kong bank account to receive foreign currency payments. But here’s a tough question: Does your Hong Kong company really ”count as a Hong Kong company” for tax purposes?

If your Hong Kong company is merely a shell entity—with no actual office, no employees, and no records of board meetings held in Hong Kong—it is highly likely to be ”pierced” during a cross-border tax audit. In other words, it will be deemed to be, in substance, a mainland Chinese enterprise, thereby facing the risk of having to pay the full amount of back taxes.

The Certificate of Residence (CoR) for Hong Kong tax residents is the key document used to close this loophole. For cross-border e-commerce sellers, it directly determines whether you can preserve your profits in the following three scenarios.

If you have a Hong Kong company—or even a Hong Kong bank account—do you think that means you’re all set when it comes to compliance?

In 2026, with the global implementation of CRS 2.0 and the data transparency measures under Phase IV of the Golden Tax Project, an increasing number of people with Hong Kong accounts will receive notices from mainland tax authorities stating: ”Please provide details regarding your overseas income.” At that point, what will be your most reliable safeguard to prove your compliance?

The answer is: the Certificate of Resident Status (CoR). It’s more than just a piece of paper—it may be the key document you need to maintain Hong Kong’s low-tax advantages, enjoy the benefits of cross-border tax treaties, and comply with CRS information exchange requirements.

Many people register a Hong Kong company to save a fortune on the matter of address, and later realize that the price paid is much more than the savings.

Today to speak clearly: how to choose a registered address, virtual address and physical address in the end where the difference.

Can a Hong Kong company be left alone after registration if it does not actually operate? The answer is no. Letting things go will not only incur fines, but may also lead to the company being forced to be struck off and the credit of the directors being damaged. This article explains the compliance exit program in detail.