Effective from 10 November 2025, the Hong Kong Inland Revenue Department (IRD) will issue only digital Certificates of Resident Status (CoR) to entities and individuals under the double tax arrangement between the Chinese Mainland and the Hong Kong SAR (the “Mainland/HK DTA”).1 Paper CORs will no longer be provided for applications under the Mainland/HK DTA.
WHY THIS MATTERS
The introduction of the digital CoR is expected to streamline administrative procedures for claiming treaty benefits within mobility programmes. Employers and globally mobile employees who rely on Hong Kong SAR tax residency to access reduced withholding rates or exemptions under bilateral tax treaties, will need to review and adjust processes in view of the new requirements.
Key Highlights
The IRD announced on its webpage on CoR (marked as NEW on the webpage) that, effective from 10 November 2025, digital CoRs (or e-CoRs) will be issued to entities and individuals upon their successful CoR applications under the Mainland/HK DTA.
- Currently, e-CoRs are issued in respect of the Mainland/HK DTA only. For CoRs in respect of the other double tax arrangements of the Hong Kong SAR, the IRD will continue to issue the CoRs in paper form.
- Entities and individuals can still submit a completed CoR application form under the Mainland/HK DTA to the IRD in paper form or electronically via the Business Tax Portal (BTP) or Individual Tax Portal (ITP).
- However, the IRD will no longer issue any CoRs in paper form under the Mainland/HK DTA.
- The e-CoR will be sent to the message inbox of the successful applicant’s BTP or ITP account.
- The tax representative of the CoR applicant will be able to access the e-CoR issued by the IRD in the Tax Representative Portal (TRP) if the applicant has given proper authorisation for their tax representative to do so in its BTP account.
- The Mainland tax authorities can verify the authenticity of an e-CoR by uploading the certificate to the “e-Proof” website.2
KPMG INSIGHTS
KPMG in China welcomes the IRD’s initiative to issue CoRs in digital form under the Mainland/HK DTA. This reflects the government’s commitment to streamlining tax administrative processes and improving efficiency through increased technology adoption.
KPMG in China states that:
- The new e-CoR arrangement will make it more convenient for taxpayers who need to produce the CoR issued by the IRD to multiple local tax bureaus in the Chinese Mainland.
- Additionally, the e-CoR arrangement would not affect the existing administrative arrangement under the Mainland/HK DTA whereby a CoR issued to an applicant for a particular calendar year can serve as proof of the Hong Kong resident status of the applicant for that calendar year and the two succeeding calendar years.
- However, under the new arrangement, the IRD will only issue digital CoRs to taxpayers who have successfully set up their BTP or ITP accounts. This may cause delays in the CoR issuance process in practice for taxpayers who have yet to complete their portal registration. These taxpayers should anticipate the extra time required for obtaining an e-CoR under the Mainland/HK DTA and are advised to initiate the application process as early as possible.
- We observe that certain entities and individuals are still in the process of setting up their accounts in BTP or ITP given the portals were just officially launched in late July this year and the time required for onboarding.
Steps to Consider
Taxpayers are encouraged to expedite the setting up of their BTP or ITP accounts as soon as practicable, as we anticipate that a wider range of tax administrative functions will be managed through these portals going forward.
If assignees and/or their programme managers have any questions or concerns about the scope of the directive, its application and potential impacts, and appropriate next steps, they should consult with their qualified tax or social security professional or a member of the GMS/People Services team with KPMG in China (see the Contact Us section).
FOOTNOTES:
1 Please see, Inland Revenue Department, Certificate of Resident Status.
2 Please see, “e-Proof” website.
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Disclaimer
The information contained in this newsletter was submitted by the KPMG International member firm in People's Republic of China.
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