China: income tax incentives in the Hengqin-Macau zone

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


China: income tax incentives in the Hengqin-Macau zone

Sponsored by

sponsored-firms-kpmg.png
macau-3766162.jpg

Lewis Lu of KPMG China looks at the new substance requirements and implementation rules for the preferential income tax incentives in the Hengqin-Macau cooperation zone.

China has for several years been pushing forward an economic development strategy for the Guangdong-Hong Kong-Macau Greater Bay Area. As part of this, in 2021, the Chinese government announced a plan to increase the industrial diversity of Macau, a special administrative region of China with separate regulatory and tax regimes, through building up the Hengqin-Macau cooperation zone. Hengqin itself falls under the mainland China regulatory and tax regimes. Technological R&D, high-end manufacturing, tourism, and modern finance are to be fostered, in part through several income tax incentives:

  • A reduced 15% corporate income tax (CIT) for enterprises in the encouraged industries;

  • A CIT exemption for ‘new’ foreign-sourced income received by enterprises registered in the zone and engaged in tourism, modern services and high-tech industries;

  • 100% expensing, and accelerated depreciation regimes for eligible capital expenditure; and

  • A maximum of 15% individual income tax (IIT) rate for the income of personnel with high-end and urgently needed skills; and another rule applicable to Macau residents working in the zone to lower their mainland China IIT burdens.

To supplement these incentives, the relevant government authorities recently announced the substantive operation requirements (applying from January 2023) and implementation guidance (retroactively applying from January 2021).

The substantive operation requirements aim to ensure that the benefits of the incentives can only be accessed by enterprises with a real economic link to the zone, and cannot be otherwise abused. The ‘four elements’ of these requirements (production and business operation, staff, accounting and assets) are largely consistent with the provisions introduced for the Hainan free trade port (FTP), but with a few differences.

For example, the Hengqin-Macau rule requires that individuals must pay at least six consecutive months of social security (such as pension insurance) in the Hengqin-Macau zone. By contrast, the Hainan provision needs at least 183 days of residence in a tax year to qualify for the incentives. The Hengqin-Macau rule is more in favour of enterprises and is easier to be achieved. Another difference is that the Hengqin-Macau zone sets out more specific and detailed supporting materials (such as a lease agreement for business premises, social security payment certificates) to evidence whether the above four elements are met. The evidence in Hainan FTP mainly relies on the written explanation.

In parallel, the implementation guidance also explicitly clarifies the criteria for personnel with high-end and urgently needed skills to enjoy the IIT incentives:

  • Personnel with high-end and urgently-needed skills must be engaged either in the encouraged industries (technology R&D and high-end manufacturing, Macau-branded industries, tourism and finance) and several other designated sectors (including the construction and medical fields);

  • The personnel need to genuinely work in the Hengqin-Macau zone and must have at least a one-year employment contract with enterprises that substantively operate in the zone. The enterprises must meet the substantive requirements test;

  • To be identified as personnel with high-end skills, the person is required either to be at a leading level in a field or have an annual income of no less than RMB 0.5 million ($71,000); and

  • As for the personnel with urgently-needed skills, they must either meet the education or professional or occupational requirements.

Apart from the Hengqin-Macau zone and Hainan FTP, several other special economic zones in China also offer regional preferential tax treatments. Businesses are urged to review the different tax treatment of each zone and even differences in and outside the zones before investment and business deployment, especially with a view to BEPS 2.0 global minimum tax.

more across site & shared bottom lb ros

More from across our site

Spanish-headquartered multinationals lead on reporting quality, while US and Swiss groups lag in the Fair Tax Foundation’s expanded analysis
Former IRS commissioner Danny Werfel joins ITR for a must-listen conversation spanning his time leading the agency, his AI risk framework, and the future of the OECD
Tax and legal services was PwC’s fastest-growing business line last year, helping to put the firm back on a par with its big four rivals
Ex-EY and Hourani & Partners leader Zain Satardien is using flexible staffing and AI-enabled systems to test a leaner model for specialist legal and tax advice
The big four firm is rightfully prioritising transparency and accountability as it seeks to rebuild from its scandal, but a glaring structural issue remains
A recent hiring flurry has taken the firm’s number of partner appointments this year to 121 and put it on track to hit 160 partner target early
The move brings specialist tax and litigation capability to EY as it seeks to close the gap on Baker McKenzie and Venezuela’s leading local firms
The industry’s response to AI requires an unfamiliar ingredient as firms battle to shape their futures
The ambitious big four challenger firm has also appointed ex-RSM partner Brad Ashton to build out its customs and global trade practice
The big four firm allegedly reviewed backdated documents and signed off on accounts that removed hundreds of millions of dollars of Abramovich’s assets
Gift this article