Withholding Tax For Chinese Public Listed Company
A-Share , B-Share , H-Share , Red-Chip, S-Chip and P-Chip ?
Nobody likes to pay tax and try to avoid or minimize it as much as possible , tax could be a huge cost component” and it reduce our overall rate of returns, especially if like we would have to pay 20-30% of withholding tax for capital gain or dividend income for investing in certain countries.
As you know, I have just started to invest in HKG/CHN market since Sep 2019 and still learning on different classes structure and tax issues on investing in China related companies through HKEX.
Chinese Public Listed Company Share Classes < source :yahoofinance.com>
Publicly traded companies in China generally fall under three share categories:
- A-shares represent publicly listed Chinese companies that trade on Chinese stock exchanges such as the Shenzhen and Shanghai Stock Exchanges. These stocks trade in yuan renminbi (CNY).
- B-shares are Domestically Listed Foreign Investment Shares. They list on the Shenzhen and Shanghai exchanges, and trade in foreign currencies.
- H-shares, traded on Hong Kong's exchanges, are regulated by Chinese law and are freely tradable by anyone. These shares trade using the Hong Kong dollar (HKD).
· Chinese H-shares represent the shares of publicly-traded incorporated Chinese companies listed on the Hong Kong Stock Exchange. H-shares are issued in China under Chinese law and are subject to the Hong Kong Stock Exchange's listing requirements.
· The rules state that annual accounts must follow Hong Kong or international accounting standards. Also, a company’s articles of incorporation must include sections clarifying the varying nature of domestic shares and foreign shares, including H-shares, as well as the rights given to each purchaser.
Unlike A-shares listed on the Shanghai or Shenzhen stock exchanges and trading in Chinese renminbi, H-shares quote, and trade with a face value of Hong Kong dollars. H-shares are also open for all investors to trade.
· There are usually price discrepancies between a company's A-shares and H-shares. Also, A-shares generally trade at a premium to H-shares.
We used to only be able to buy H-share listed in HKEX but with this so called “Stock Connect” programme, now we will be able to buy A share from HKEX :
WHAT IS STOCK CONNECT <source : HKEX>
A unique collaboration between the Hong Kong, Shanghai and Shenzhen Stock Exchanges, Stock Connect allows international and Mainland Chinese investors to trade securities in each other's markets through the trading and clearing facilities of their home exchange.
First launched In November 2014, the scheme now covers over 2,000 eligible equities in Shanghai, Shenzhen and Hong Kong.
From below Link , you will be able to find A-share listed on HKEX from SSE ( Shanghai Stock Exchange ) and SZSE (Shengzen Stock Exchange ).
Red Chip vs S-Chip vs P-Chip
What Is a Red Chip?
A red-chip company does most of its business in China, and the Chinese government has a considerable stake in the firm. However, it is incorporated outside mainland China and listed on the Hong Kong Stock Exchange. Red-chip stocks are expected to maintain the filing and reporting requirements of the Hong Kong exchange. That makes them an important outlet for foreign investors who wish to participate in the rapid growth of the Chinese economy.
A red-chip company does most of its business in China, and the Chinese government has a considerable stake in the firm.
Red chip firms are incorporated outside mainland China and listed on the Hong Kong Stock Exchange.
Red chips take their name from China's red flag, and the name reflects the Chinese government's partial ownership of the company.
Red-chip firms are not necessarily large or well-known.
Understanding Red Chips
Although red chips are listed on the Hong Kong Stock Exchange, they should not be confused with H-shares. H-shares are shares of companies that are incorporated in mainland China but traded on the Hong Kong Stock Exchange or another foreign exchange. Red chips, on the other hand, must be incorporated outside mainland China
Example of a Red Chip
China Mobile was the largest red-chip company as of December 2019, with a market capitalization of more than 1.2 trillion Hong Kong dollars (over 150 billion U.S. dollars). The firm was incorporated in Hong Kong in 1997, so it is incorporated outside of mainland China. The firm's shares are listed on the Hong Kong Stock Exchange, which is also required for red-chip stocks. In December 2018, 72.72% of the company was held by China Mobile Communications Group Co., Ltd., which is a Chinese state-owned enterprise.
S chips are Chinese companies listed on the Singapore Exchange. Their shares are known as S shares. S chips are incorporated in Singapore, the British Virgin Islands, the Cayman Islands and Bermuda and have their business operations in mainland China.
Some S chips were beset by corporate governance and accounting problems, resulting in reputational issues that led to share price declines in 2009. 
The term P chip refers to Chinese companies (non-state own enterprises ) listed on the Hong Kong Stock Exchange which are incorporated in the Cayman Islands, Bermuda and the British Virgin Islands with operations in mainland China, and are run by private sector Chinese businessmen. During the financial crisis of 2007–2010, P chips showed a dramatic increase in the rate of bankruptcy failures as compared to H shares or red chips.
The main difference between S chips and P chips is the exchange on which they are traded.
As we know, in some countries, we will need to pay withholding tax for dividend received from companies we invested in foreign country. It could be as high as 30% (eg from US )
For China related stocks , A-share , B-share and H-share are subject to a 10% withholding tax while P-Chip , Red Chip and S-Chip are subject to a 0% withholding tax, unless a specific withholding tax of 10% is announced by the companies.
You may find link useful :
Dividend Withholding Tax Table ( From ICE Data Index ,LLC )
In summary , to avoid any confusion of class of share like A, B, H or different kind of “Chips” , you may just look out for the “Place of Incorporation “ in their respective Annual Report or Interim Result announcement. For those having “Place of Incorporation “outside PRC like Bermuda / Cayman Island / Singapore / Hong Kong ) , there will be no withholding tax for dividend.
Hope this assist and clarify.
This will probably be my last blog post in 2019 , taking this opportunity , I would like to wish you and your family a joyful, bright, healthy, prosperous and happiest new year ahead! Happy New Year 2020!
Withholding Tax could be quite substantial and affecting your overall dividend yield by more than 1% point if your stock’s dividend yield is high ( eg. 10% -> 9% )
Below just an example of two stocks I have invested , one with Withholding Tax and the other without tax.