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]

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 these︀ two countries, which I think there is, then you have to look there as well︁ for a PE article or similar. However whatever the applicable rules, such matters boil down︂ to the specifics of the operation and how it is conducted as a small change︃ in the operation can alter the taxabily of something.