The first-two-years compliance calendar for a new Hong Kong export company
Setting up a Hong Kong company to sell on Alibaba.com is quick. Keeping it in good standing is a series of small, dated obligations that are easy to forget in year one, when everyone is focused on the store, the factory and the first orders. Missing them rarely ends a business, but late filings bring penalties, and an out-of-date company record can slow down a bank review or a platform verification right when you need it.
Here is the first-two-years compliance calendar we walk new Hong Kong export companies through. It is general information to help you plan, not tax or legal advice.
Standing requirements from day one
These aren't dated events, but they must be true all the time:
- Registered office in Hong Kong. A real address where official letters can be served.
- Company secretary. A Hong Kong resident individual or a Hong Kong company. Many small companies use a licensed trust and company service provider (TCSP) for this.
- Significant Controllers Register (SCR). Kept at the registered office or a prescribed place and updated when ownership changes.
- Statutory registers and minutes. Directors, members, and resolutions for major decisions (opening bank accounts, appointing auditors, signing big contracts).
- Proper books and records. Sales invoices, purchase invoices, contracts, shipping documents and bank statements, kept for at least seven years.
For an exporter, “proper records” means the contract, the invoice, the shipping documents and the payment all line up under the same company names. That consistency is what auditors, the tax office and banks all look for.
Event-driven filings (whenever something changes)
- Change of directors or secretary: notify the Companies Registry within 15 days (form ND2A).
- Change of registered office address: notify within 15 days (form NR1).
- New shares issued: return of allotment within one month (NSC1).
- New employee: notify the Inland Revenue Department within three months of the start date, and enrol them in an MPF scheme within the enrolment deadline.
If you're also running an Alibaba.com store or other platform accounts under this entity, update those records at the same time so names and addresses stay consistent.
Annual events
Business Registration renewal. The BR certificate must be renewed before it expires (annually, or every three years if you chose the three-year option). The renewal demand arrives by post, so make sure mail at your registered office actually reaches someone.
Annual Return (NAR1). A private company files its annual return with the Companies Registry within 42 days after each anniversary of its incorporation date. Late filing fees escalate quickly, so put this in the calendar on day one.
Audited financial statements. Hong Kong companies must have their annual financial statements audited by a Hong Kong certified public accountant. Small private companies can use a simplified reporting framework, but the audit itself is still required. Book your auditor early: the busy season runs from roughly August to November.
Employer's Return (BIR56A). If you have employees, the IRD issues this every April and it's due within one month.
Profits tax: what to expect in the first two years
- The first Profits Tax Return is normally issued around 18 months after incorporation. It covers your first accounting period, which can be longer than 12 months.
- After that, returns are issued annually, typically at the start of April. The standard deadline is one month, and tax representatives can often get longer extensions under the IRD's block extension arrangements.
- Rates. Hong Kong uses a two-tiered system for corporations: 8.25% on the first HK$2 million of assessable profits and 16.5% on the rest. Only one entity in a group of connected companies can claim the lower tier.
- Territorial basis. Only Hong Kong-sourced profits are taxed. Some trading companies make an “offshore claim” arguing that their profits are sourced outside Hong Kong. These claims are reviewed closely and need solid evidence of where contracts were negotiated, concluded and performed. Even with an offshore claim you still need audited accounts and must file returns.
A simple year-one calendar
| When | What |
|---|---|
| Month 0 | Incorporate; open SCR and registers; appoint company secretary; open bank account |
| Month 0–1 | Set up bookkeeping; decide financial year-end; collect contracts and invoices from day one |
| Within 3 months of hiring | Notify IRD of new employees; MPF enrolment |
| Anniversary + 42 days | File Annual Return (NAR1) |
| Before BR expiry | Renew Business Registration |
| After first year-end | Engage auditor; prepare accounts |
| Around month 18 | First Profits Tax Return issued; file with audited accounts |
| Every April | Employer's Return; subsequent Profits Tax Returns |
How this connects to selling on Alibaba.com
Platform verification and buyer trust both depend on your company record being current. A Hong Kong entity with an expired BR or a director change that wasn't filed can cause friction when you renew a membership, add verification, or when a buyer checks your company. Keeping the corporate calendar and the store records in sync avoids that.
If you're still deciding how to structure a Hong Kong entity for export, we've summarised company setup, bank account and ongoing secretarial support on our site, along with our general guide to opening Alibaba.com with a Hong Kong company.
Written by the team at Corpable Marketing Limited, an Alibaba.com authorized channel partner in Hong Kong, working with a licensed TCSP on company secretarial matters. Deadlines and rules change; always confirm current requirements with the Companies Registry, the Inland Revenue Department or your accountant.