尽管中国政府对内地居民通过离岸信托转移的海外房产所得租金收入和资本收益征收20%的税，但中介表示，这些投资者仍然是香港房地产市场的关键驱动力。
Although the Chinese government imposed a 20 per cent tax on rental income and capital gains derived from overseas properties transferred into offshore trusts by mainland residents, agents said these investors remained a key driver of the Hong Kong property market.
中国财政部和国家税务总局7月表示，内地中国居民通过离岸信托或海外控股公司持有的房地产、股票或股权等资产所产生的租金收入、房产出售利润和投资收益，现在须按20%的税率缴纳个人所得税。
China’s Ministry of Finance and the State Taxation Administration said in July that rental earnings – profits from the sale of properties and investment gains derived from assets including real estate, stocks or equity interests held by mainland Chinese residents through offshore trusts or overseas holding companies – were now subject to individual income tax at a rate of 20 per cent.
新规则为纳税人提供90天的合规窗口，允许他们自愿向内地税务机关申报并缴纳任何未缴税款，截止日期为10月22日，以换取免除罚款。
The new rule provides taxpayers with a 90-day compliance window, allowing them to voluntarily declare and pay any outstanding taxes to mainland tax authorities – up until the October 22 deadline – in exchange for an exemption from penalties.
利嘉阁地产高级副总监林锦霞透露，中国内地宣布的新税收规定也打击了香港房地产市场，但市场迅速吸收了影响。
Kit Lam, senior associate director at Ricacorp Properties, revealed that the new tax regulations announced by mainland China also hit the Hong Kong property market, but the market quickly absorbed the impact.
“近几个月，内地中国买家占新界较小型入门级房产（如屯门和天水围的房产）交易的约15%至20%，”她说。
“In recent months, mainland Chinese buyers have accounted for about 15 to 20 per cent of transactions for smaller, entry-level properties in the New Territories, such as those in Tuen Mun and Tin Shui Wai,” he said.
“这些购买大多是为了自用，例如，方便子女在香港接受教育。这类实际需求者受影响最小，最近内地买家的询盘有所增加。”林锦霞解释说，内地人士购买香港住宅物业的主要原因，例如子女跨境教育需求和资产配置，依然存在。
“Most of these purchases are for personal use, for instance, to facilitate their children’s education in Hong Kong. This group of end users is the least affected, and there has recently been an uptick in inquiries from mainland buyers.”The primary reasons for mainlanders to purchase residential property in Hong Kong, such as the need for cross-border education for their children and asset allocation, remained in place, Lam explained.
“许多内地买家只是调整其持有比例，而非完全放弃香港房地产市场，”她指出。
“Many mainland buyers are simply adjusting the proportion of their holdings, rather than abandoning the Hong Kong property market entirely,” he noted.
税务公告发布后，香港住宅物业交易总量暴跌47.5%，从6月的年内高点7650套降至8月的年内低点4019套。
Following the tax announcement, the total volume of residential property transactions in Hong Kong plummeted by 47.5 per cent, dropping from a year-to-date high of 7,650 units in June to a year-to-date low of 4,019 units in August.
中原地产数据显示，总交易额也下跌52.1%，从6月的756亿港元（约合96亿美元）降至8月的362亿港元低点。
The total transaction value also fell by 52.1 per cent, declining from HK$75.6 billion (US$9.6 billion) in June to a low of HK$36.2 billion in August, according to data from Centaline Property.
但数据显示，9月住宅物业总交易量环比反弹18.5%，达到4761套，总交易额也上涨29.3%，达到468.1亿港元。
But the data showed that the overall volume of residential property transactions in September rebounded by 18.5 per cent month-on-month to 4,761 units, while the total transaction value also rose by 29.3 per cent to HK$46.81 billion.
几位来自中国大陆的个人因该问题敏感而要求匿名，他们透露，中国大陆政府从未试图征收20%的个人所得税，尽管他们持有的用于投资和出租的香港住宅物业均以个人名义登记。
Several individuals from mainland China, who requested anonymity due to the sensitivity of the issue, revealed that the mainland Chinese government had never sought to collect a 20 per cent personal income tax although the Hong Kong residential properties they own for investment and rental purposes were held in their personal names.
实际上，他们说，他们并未主动申报收入，因为涉及众多部门且审计流程冗长繁琐的跨境事务，追踪交易非常困难。
In reality, they said that they did not proactively declare the income, as it was very difficult to track transactions down due to the complexity of cross-border matters that involved numerous departments and lengthy, cumbersome audit processes.
美联物业高级董事总经理钟齐全解释称，根据中国大陆的个人所得税制度，20%的税率仅针对资产收益征收，仅持有物业本身不会触发征税。
Henry Chung, senior managing director at Midland Realty, explained that under mainland China’s personal income tax regime, a 20 per cent tax was levied only on gains derived from assets, while the mere act of holding property did not trigger taxation.
“中国大陆和香港有避免双重征税协定（DTA），”他解释道。“当中国大陆居民在香港出租房产时，业主必须先向香港税务局缴纳15%的物业税。”他说，在内地申报这笔收入时，业主有权就已缴纳的金额抵免税款，他们只需向内地税务机关补缴差额，而无需再缴纳额外的20%税款。
“Mainland China and Hong Kong have an agreement for the avoidance of double taxation (DTA),” he explained. “When a mainland resident rents out a property in Hong Kong, the owner must first pay a 15 per cent property tax to the Hong Kong Inland Revenue Department.”Upon declaring this income on the mainland, the owner is entitled to a tax credit for the amount already paid, he said, as they were only required to pay the difference to the mainland tax authorities, rather than paying an additional 20 per cent tax.
耀才地产大湾区区域投资总监刘景表示，新规则公布后，中国大陆购房者原本计划暂缓在香港购房的计划。
King Lau, regional investment director for the Greater Bay Area at Yui Yin Property, said that mainland Chinese had planned to put their plans of buying property in Hong Kong on hold after the new regulations were announced.
“目前大多数内地买家对新规则仍持谨慎态度，”他补充道。“他们继续看房，同时采取‘观望’态度，看看这些规定实际执行得有多严格。”本月房地产市场继续升温。上周六，西贡路Sierra Sea第2C(2)期和油塘The Atlas第1期两个新盘分别推出142个和220个单位公开发售，两个项目当天全部售罄。
“Now most mainland buyers remain cautious regarding the new rules,” he added. “They are continuing to view properties while simultaneously taking a ‘wait-and-see’ approach to observe how strictly the regulations are actually enforced.”The property market continued to warm up this month. Last Saturday, two new residential projects – Phase 2C(2) of Sierra Sea on Sai Sha Road and Phase 1 of The Atlas in Yau Tong – launched 142 and 220 flats for public sale, respectively. Both projects sold out completely on the same day.
The Atlas的开发商岳秀地产表示，本月早些时候该项目首轮销售期间，30%的买家来自中国大陆和外国。
Yuexiu Property, the developer of The Atlas, has stated that during the first round of sales for the project earlier this month, 30 per cent of the buyers were from mainland China and foreign countries.