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Summary
Effective from 10 November 2025, the Hong Kong Inland Revenue Department (IRD) will only issue digital Certificates of Resident Status (CoR) to entities and individuals under the double tax arrangement between the Mainland and the Hong Kong SAR (the Mainland/HK DTA). Physical certificates will no longer be provided for applications under the Mainland/HK DTA.
In this tax alert, we summarise the new digital CoR arrangement and share our observations.
The issuance of digital CoRs
The IRD announced on its webpage on CoR (marked as NEW on the webpage)1 that, effective from 10 November 2025, digital CoRs (or e-CoRs) will be issued to entities and individuals upon their successful CoR applications under the Mainland/HK DTA. We highlight below the key points of this new e-CoR arrangement.
- Currently, e-CoRs are issued in respect of the Mainland/HK DTA only. For CoRs in respect of the other double tax arrangements of the Hong Kong SAR, the IRD will continue to issue the CoRs in paper form.
- Entities and individuals can still submit a completed CoR application form under the Mainland/HK DTA to the IRD in paper form or electronically via the Business Tax Portal (BTP) or Individual Tax Portal (ITP).
- However, the IRD will no longer issue any CoRs in paper form under the Mainland/HK DTA.
- The e-CoR will be sent to the message inbox of the successful applicant's BTP or ITP account.
- The tax representative of the CoR applicant will be able to access the e-CoR issued by the IRD in the Tax Representative Portal (TRP) if the applicant has given proper authorisation for their tax representative to do so in its BTP account.
- The Mainland tax authorities can verify the authenticity of an e-CoR by uploading the certificate to the "e-Proof" website2.
KPMG observations
We welcome the IRD's initiative to issue CoRs in digital form under the Mainland/HK DTA. This reflects the government's commitment to streamlining tax administrative processes and improving efficiency through increased technology adoption. The new e-CoR arrangement will make it more convenient for taxpayers who need to produce the CoR issued by the IRD to multiple local tax bureaus in the Mainland. Additionally, the e-CoR arrangement would not affect the existing administrative arrangement under the Mainland/HK DTA whereby a CoR issued to an applicant for a particular calendar year can serve as proof of the Hong Kong resident status of the applicant for that calendar year and the two succeeding calendar years.
However, under the new arrangement, the IRD will only issue digital CoRs to taxpayers who have successfully set up their BTP or ITP accounts. This may cause delays in the CoR issuance process in practice for taxpayers who have yet to complete their portal registration. These taxpayers should anticipate the extra time required for obtaining an e-CoR under the Mainland/HK DTA and are advised to initiate the application process as early as possible.
We observe that certain entities and individuals are still in the process of setting up their accounts in the BTP or ITP given the portals were just officially launched in late July this year and the time required for onboarding. To ensure a smoother transition, it would be helpful if the IRD could consider certain transitional measures, such as introducing a transitional period during which taxpayers are allowed the option to receive the CoR under the Mainland/HK DTA in paper or digital form.
We also encourage taxpayers to expedite the setting up of their BTP or ITP accounts as soon as practicable, as we anticipate that a wider range of tax administrative functions will be handled through these portals going forward.
Footnotes
1. The IRD's new e-CoR arrangement can be accessed via this link: https://www.ird.gov.hk/eng/tax/dta_cor.htm
2. The "e-Proof" website can be accessed via this link: https://www.eproof.gov.hk/en/verification.
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