The concept of a Hong Kong offshore company will only be valid after acceptance of the offshore profits claim.
The incorporation of a Hong Kong company is the same whatever its future use as a Holding Company , a Special Purpose Vehicle , a trading or consulting company etc..
The Company can’t be legally defined as a Hong Kong Offshore Company from its incorporation process. Only after deployed activities and when preparing , a maximum of 18 months after inception, the Company audit the Company will be then in a position to claim offshore profits.
Its a claim, this means that the Hong Kong offshore profits claim could be questioned and so ..rejected.
The Company should be prepared to demonstrate the absence of activities in Hong Kong and the process should be repeated as a company could change its business models and activities.
The Hong Kong offshore Company concept also trigger additional and complex questions as if the company doesn’t have activities in Hong Kong the effective place of management should be located somewhere else.
When Hong Kong isn’t the effective place of management , if the offshore profit claim is accepted by the Inland Revenue Department, then the Company will be exempt of profits tax in Hong Kong.
Hong Kong with notable absence of VAT and Capital Gain has anyway a low tax and pro-business environment.
Paying profits tax in Hong Kong is advantageous, only 8.25 % till USD 250,000 and 16.5 % after this threshold.