Raymond Ng
Territorial tax positions, DTA access, holding structures, bank onboarding.
About
Raymond advises on holding structures and tax positions built around Hong Kong's territorial system.
He plans foreign-sourced income positions, treaty access and substance requirements, and supports clients through bank onboarding — the stage where structures most often fail.
He is the partner clients call before they incorporate anything.
Practices
Holding Structures
Holding and trading structures through Hong Kong and supporting offshore centres: ownership layers, foreign-sourced income positions, treaty access and bank onboarding.
Tax Positions
Written tax positions and opinions on Hong Kong's territorial system: source of income, offshore claims, treaty access and cross-border planning. Advisory only.
Capital Relocation
Moving assets and capital into a neutral jurisdiction: relocation roadmaps, source-of-funds dossiers, KYC and UBO documentation, re-domiciliation and banking setup.
Tell us about your matter.
A written assessment of your position and options is the usual first step.