	Singapore	Hong Kong
Year of Inception Scheme	2017	Proposal
Estimated Time Taken to Complete	Two (2) months from submission of all required documentation.	Two (2) weeks from submission of all required documentation.
License Applications for regulated activities	Referrals to the relevant Agencies will be made by the Registrar	Application for relevant licence(s) separately
Application Fee	Non-refundable fee of SGD1000/-	Fee is not yet announced
Entities Allowed	Bodies corporate that can adapt their legal structure to the companies below:	Entity type is substantially the same as the companies of the following type:
Entity Re-domiciles as	Public Company Limited by Shares; or Private Company Limited by Shares	private companies limited by shares; public companies limited by shares; private unlimited companies with a share capital; and public unlimited companies with a share capital
Legal Status	A foreign corporate entity that re-domiciles to Singapore will become a Singapore company and be required to comply with the Companies Act like any other Singapore incorporated company. Re-domiciliation will not affect the obligations, liabilities, properties or rights of the foreign corporate entities.	Legislation will provide that re-domiciliation will not create a new legal entity, and will not affect the property, rights, obligations and liabilities, as well as the relevant contractual and legal processes of the companies.
Size criteria	The entity must meet any two of the below criteria: the value of total assets exceeds S$10 million; the annual revenue exceeds S$10 million; more than 50 employees; An applicant which is a parent will be assessed on a consolidated basis even if subsidiaries are not re-domiciling. An applicant which is a subsidiary is assessed as a single entity. Alternatively, subsidiary meets the size criteria if its Parent (being a Singapore entity by incorporation or transfer) meets the size criteria.	Not mentioned.
Solvency Criteria	The foreign entity meets local solvency criteria, (i.e. able to pay its debts as they fall due during the period of 12 months after the date of the application; are not under judicial management, liquidation or being wound up etc
Member and Creditor Protection	The transfer must be done in accordance with the law of the original jurisdiction, including such member and creditor protections as may be applicable. The application for transfer of registration is — not intended to defraud existing creditors of the foreign corporate entity; and made in good faith; and as at the date of the application, first financial year end at its place of incorporation has passed	If neither the law of the original domicile nor the constitutional documents of the applicant requires it to obtain member’s consent, then Hong Kong requires members’ consent by a resolution duly passed by at least 75% of the eligible members by meeting or written resolution. The application for transfer of registration is — not intended to defraud existing creditors of the foreign corporate entity; and made in good faith; and as at the date of the application, first financial year end at its place of incorporation has passed
Laws of Original Jurisdiction permits re-domiciliation outward	Required	Required
Re-domiciliation out of Singapore/Hong Kong	Not allowed	Not allowed
Effect of the Re-domiciliation on Tax etc	S 34G Singapore Income Tax Act (SITA) provides for transitional tax matters. Generally speaking, from the date of re-domiciliation, the treatment of trading stock, expenditures, depreciation allowances etc., are treated in alignment with the Singapore Tax system. 34H SITA provides for tax credits that can be awarded to companies successful in their re-domiciliation to Singapore. Generally speaking, such credits provide relief of exit taxes on deemed income in the entity’s original jurisdiction. No Stamp Duty liabilities will arise.	The re-domiciliation process should not affect the companies’ tax obligations in the jurisdiction of their original domicile to, e.g.,avoid the risk of the process being used for tax evasion. The Inland Revenue Ordinance (IRO) will be amended to address transitional tax matters in a comprehensive manner with reference of comparable jurisdictions’ arrangements. The amendments will cover fair deduction for trading stock, specified types of expenditures, depreciation allowances etc., as such elements that may have occurred before re-domiciliation would have to be taken into account for tax assessment after re-domiciliation IRO will be amended to provide for transitional tax matters e.g. unilateral tax credits will be provided for the re-domiciled company in respect of exit taxes from unrealised profits taxed in the company’s original domicile. No Stamp Duty liabilities will arise since the re-domiciliation process will not entail any transfer of a company’s asset or change in the beneficial ownership of a company’s asset.
Compliance after Re-domiciliation (i.e. appoint directors, secretaries etc)	In accordance with Singapore law commencing from issuance of certificate of re-domiciliation, and notice of transfer.	In accordance with Hong Kong law commencing from issuance of certificate of re-domiciliation.
Duration to submit proof of deregistration from original jurisdiction to Authorities	60 days after notice of transfer unless extended	120 days after date of re-domiciliation unless extended
Documentary Proof	Entity’s constituting documents Undertaking to provide audited financial statements of the last financial year; Declarations by relevant officers/agents; Declaration by directors of foreign entity that the entity meets the criteria for re-domiciliation.	Entity’s constituting documents Financial Statements not more than 12 months prior to application date (does not need to be audited if its original jurisdiction does not require the accounts to be audited) Legal opinion in relation to solvency of applicant; Relevant resolution; Legal Practitioner’s opinion that the proposed re-domiciliation is allowed under the law of the original domicile