According to the relevant provisions of the Enterprise Income Tax Law and the Regulations for the Implementation of the Enterprise Income Tax Law, if there is no institution or place in China, or if there is an institution or place, but the income obtained is not actually related to the institution or place, the applicable tax rate is 20%, and the enterprise income tax is levied at a reduced rate of 10%. At the same time, non-residents who have tax obligations in China can apply for tax treaty treatment if they come from countries that have concluded tax treaties with China. If the income from dividends, bonuses, interest, etc. of non-resident enterprises in countries with which China has concluded tax treaties is less than 10% according to the restrictive tax rate stipulated in relevant tax treaties, they can enjoy the agreed tax rate upon the application of the enterprise and the examination of the competent tax authorities. If the tax rate stipulated in the tax treaty is higher than that stipulated in China's domestic tax laws, the taxpayer can still pay taxes according to China's domestic tax laws.

The preferential policies that may also be applicable to the above-mentioned cases of Hong Kong companies include the provisions on dividends in Item 2 of Article 10 of the Arrangement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion on Income between the Mainland and the Hong Kong Special Administrative Region.

1. Dividends paid by a resident company of one party to the residents of the other party may be taxed in the other party.

2. However, these dividends can also be taxed in accordance with the laws of the party where the company paying the dividends is a resident. However, if the beneficial owner of the dividend is a resident of the other party, the tax payable shall not exceed the following requirements, that is, if the beneficial owner directly owns at least 25% of the shares of the dividend-paying company, it shall be 5% of the total dividend. In other cases, it is 10% of the total dividend.

However, the premise is to meet the conditions stipulated in the Notice of State Taxation Administration of The People's Republic of China on Relevant Issues Concerning the Implementation of Dividend Clauses in Tax Treaties (Guo Shui Han [2009] No.81), including:

1. The company in Hong Kong is a resident company in Hong Kong.

2. The beneficial owner of dividends distributed by this company is a Hong Kong company.

3. A Hong Kong company has owned more than 25% of all shareholders' equity and voting shares of the company at any time during the continuous 12 months before receiving the dividend. And in accordance with the provisions of the relevant provisions of the document to apply for relief. Enterprises applying for tax treaty (arrangement) treatment shall be implemented in accordance with the relevant provisions of the Notice of State Taxation Administration of The People's Republic of China Municipality on Printing and Distributing the Administrative Measures for Non-residents to Enjoy Tax Treaty Treatment (Trial) (Guo Shui Fa [2009]124).