Hong Kong: 选择合适的地点,受惠于亚洲航空金融的繁荣

Last Updated: 5 February 2019
Article by Kevin Butler

Most Popular Article in Hong Kong, February 2019

由于中国、印度和其他区域市场的航空旅游蓬勃,航空金融业持续在亚洲扩张,更吸引了越来越多的飞机租赁商考虑在亚洲开展业务,以便夺得先机。

TMF Group与《航空金融》杂志共同举办了一个网络研讨会——"天津东疆保税港区(下称东疆)与香港——选择最适合的飞机租赁地点"。行业专家聚首一堂,集中讨论中国自由贸易区的优势,特别是为飞机租赁领域提供平台的东疆和香港;专家也提供了挑选区域基地的实用建议。

竞争与互补

瑞栢律师事务所合伙人刘屹律师指出,东疆是中国政府指定的航空金融枢纽,也是迄今众多本地自由贸易区中最成功的航空金融基地。这有赖于稳健的基建和商业便利政策。

2018年6月,东疆成功交付了1200架飞机,总值超过4500亿人民币,而且提供了数个相当诱人的优惠。 租赁飞机进口无需缴纳增值税(VAT),而预付税也由中国承租人缴付。出租者享有办公室租金补贴,高级行政人员也能获得个人所得税退税。另外,出租者也能获得人民币融资,因中国航空业者倾向于以人民币支付租金,这是一个绝大的优势。

然而,在东疆成立业务也意味着企业需要遵守中国资金和外汇流动的限制。刘屹表示,最主要的缺点在于税务优惠政策并没有纳入法例,意味着业界有可能会受到临时更改的影响。

香港在2017年通过新税务机制吸引飞机租赁者,目前看似正超越东疆的表现。香港也有其他优势,如普通法司法管辖区、低监管障碍和整体营商便利。

针对香港高度发展的航空金融基建,金杜律师事务所合伙人Tejaswi Nimmagadda表示,香港也有提供人民币融资,而且,香港没有像大陆般实行资金上的流动限制。

毕马威税务合伙人John Timpany补充,香港作为宜居城市的吸引力,也为该增长迅速的行业吸引不少专才。

同时,专家们也发现了香港和东疆之间有互补的潜力,两者能以出租者的利益为出发点,在政策上进行协调。这与香港辅助中国一带一路和大湾区的方式大致相同,即香港作为枢纽,去吸引投资者参与这些项目。

东疆和其他自由贸易区的主要服务对象是国内市场,而香港则是作为与区域航空业者合作的外国出租者及有意走出饱和国内市场的中国企业的基地。刘屹透露,在爱尔兰营运的中国出租者也被香港的边际税务优惠、邻近的地理位置、共通的语言和商业文化所吸引。

Timpany指出,出租者的最终决定取决于客户的需求,并强调中国航空业者倾向于选择基地位于自由贸易区的出租者,以减轻他们的税务责任。

TMF Group英国及爱尔兰的董事经理Kevin Butler,作为这次网络研讨会主持人,也表示同意:"我们需要确保客户位处行业的前线和中心位置。"

门户因素

税务对出租者和他们的客户均会带来影响,乃挑选合适区域的关键因素。

作为行业领先者,爱尔兰是世界上90%出租者的"东家",全赖其72个双边税务协定。相比之下,香港只有40个税务协定。而中国的自由贸易区则有105个双边税务协定,但是,专家指出,这些合约的质量是隐忧。这促使中国出租者迁移到香港或爱尔兰。这样一来,他们在保留中国自由贸易区的据点之际,也能获取国际业务。

另外,遵守国际税务公约也是个优势之一。举例而言,香港符合经合组织的税基侵蚀和利润转移条例,若再采纳开普敦公约,香港的吸引力无疑会进一步提升。开普敦公约主要是统一规范购买和使用高价值航空设备的税务协定。

正如Timpany所说:"若你无法搞懂税务,那你并不在这场游戏内。"

前景明朗

近几年,飞机租赁市场的增长几乎没有出现放缓的迹象,我们的专家一致认为,新司法管辖区仍有充足的发展机会。其中,营运基建、法律框架、人才供应和政府的支持是成功的重要基石。

争夺枢纽地位并不是个"零和游戏"。参与研讨会的成员表示,香港和大陆的共存都是为了让出租者实现主要的目标——以最优惠的价格向客户提供飞机。

Nimmagadda强调,寻找一个具有相关知识的伙伴,能确保公司合规,因为管理各地租赁活动的税务和监管制度均获得快速发展。寻求伙伴协助能帮助出租者避免合规失误,并为他们的目标和客户群建立最佳结构。

Butler表示:"香港和东疆的发展前景明朗。"这些司法管辖区将共存互补,为投资者提供最佳解决方案。

与TMF Group联系

TMF Group在全球有超过80个司法管辖区设有办事处,包括 香港和东疆。无论客户选择哪一个枢纽,我们都能帮助您在这发展迅速的飞机租赁市场中应对挑战和把握机遇。欢迎 与我们联系,了解本地专家能如何为您的业务提供协助。

您可以在这里收听整场网络研讨会。

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