Hong Kong's corporate group structure: A call for a tax consolidation regime

The Hong Kong stock market is the seventh largest in the world in terms of market capitalization and represents 7% of the global market. Hong Kong has been considering the introduction of a group taxation regime for the past few years. While there are research studies on corporate group internationally and also on the use of group structure in a particular country (e.g., Australia), little is known about the popularity and the key features of the corporate group structures in Hong Kong. This paper intends to fill the gap by providing evidence on the extent of which corporate group structures are used in Hong Kong. Three hundred companies -- 100 each from large, medium and small companies -- listed in the Hong Kong Stock Exchange are selected for analysis of their corporate structures. Group taxation regimes represent a spectrum of applications of the doctrine to different extents, ranging from a group loss relief regime to a full consolidation regime.