Territorial tax (e.g. HK/SG) - Tax payable by non-resident for income derived from locals?

[euinchina]

If I have a UAE company (zero taxes) that accepts customers from HK/SG (territorial tax regime) through internet sales, does the UAE company need to pay tax to HK/SG for the portion of income that was derived from that country?

 

[CyprusLawyer101]

euinchina said:
If I have a UAE company (zero taxes) that accepts customers from HK/SG (territorial tax regime) through internet sales, does the UAE company need to pay tax to HK/SG for the portion of income that was derived from that country?
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It depends whether the operation qualifies to a taxable presense. Similar to a PE, but under local HK rules. Usually Hong Kong looks at whether the relevant person carries on a trade, profession or business in Hong Kong wherefrom profit arises and those profits can be considered as deriving from Hong Kong sources. If there is a DTTreaty between these two countries, which I think there is, then you have to look there as well for a PE article or similar. However whatever the applicable rules, such matters boil down to the specifics of the operation and how it is conducted as a small change in the operation can alter the taxabily of something.