Hong Kong (HK)

Jurisdiction Overview

188 *Is there an obligation to keep accounting data? Unknown
 Data Date: 2018


In 2011 the Global Forum reported that companies are obliged to keep proprer accounts and also "underlying documentation such as vouchers, bank statements, invoices, receipts, and other documents necessary to verify the entries in the books of account" (GF 2011: 49).
However, in 2019, the Global Forum reports there was a potential problem with monitoring: "Since the majority of the companies in Hong Kong are private companies that need not submit financial statements annually to the CR [Companies Registry], the IRD [Inland Revenue Department] is the main supervisory authority in Hong Kong to ensure the compliance of all relevant entities and arrangements in line with ToR A.2. The IRD’s compliance regime is mainly based on desktop review, risk-based desk audit, field audit and investigation. It is seen that some 98 000 companies on average during the years of assessment 2014/15 to 2016/17, representing about 8% of the registered companies, were subject to the aforesaid review and audit. Further, it is seen that on average only 0.27% of the cases under the aforesaid review and audit resulted in penalties for not maintaining proper accounting records. Certain entities and arrangements (including those solely earning non-taxable income) are only required to file tax returns every two to three years but not annually. This may pose a risk to the maintenance of reliable accounting records at all times." (GF 2019: 62; [TJN's-note]). Therefore, it is not clear if the obligation to keep underlying documentation is sufficient.


GF 2013: 69-75
GF 2011: 49-51
GF 2019: 62-63