大蝦碌

今日大市成交因為建行股東爭相減持,令金額突破千四億,不過講到焦點,反而係一隻停左牌嘅股分。

941中移動原定今日除息既、但突然停牌,可以話係「非常突然」。

同中移動相關衍生工具,都要跟停,買左中移動正股對沖既輪商,資金亦都責住左。

難怪市場批評,中移動處理混亂!

事件起因,係中移動話,要向內地交股息稅,要求押後除息日。

係中移動話按內地要求,股東要俾股息稅,佢地會因應呢個情況,押後除息日。

根據港交所規定,更改除息日,最少要六個交易日前通知,由於中移動星期2晚近十一點先發出通告,港交所上晝睇過後認為有問題,主動接觸中移動,導致臨時停牌。

據了解,中移動一直以為可以就股息稅問題,同內地當局達成豁免協議,但最後發現唔得。

不過相信股東最關心,係會唔會收少股息。

瑞信話,以中國電信早前經驗嚟睇,實物股東照計唔會受影響,但透過銀行證券商持有股東,因為係「非居民機構」持股,收嘅股息就要至少打九折,即係每股由原本「個4」,變為最多收到「1.2636」元,而股息率就相應會下降到百分3.2。美銀美林亦批評,中移動今次「蝦碌」係令人相當意外,有機會成為市場造淡籍口。

咁如果真係透過銀行同證券行持有中移動,咁咪要比股息稅? 有無辦法唔使比?

我地都問過會計師,佢地建議,先向券商/銀行了解,佢地股票係咪透過投資公司持有。

如果係,又想收足股息,可以考慮提倉,向中央證券登記申請,轉為以個人名義持有,期限係5月26日4點半前。

預計派息日,亦由原定六月三日,延遲到六月十二日左右。

不過留意埋,今次中移動停牌可能真係太震撼,連青啤同亮煤都要出通告,講明末期息H股嘅「非居民股東」將需扣稅一成,相信同類蝦碌會陸續有嚟。

留言

匿名說…
所知絕非蝦碌,而是一堆上市公司刻意搏懵,搏內地稅局睇唔到佢地特登唔代預扣股息稅而已。

內地稅局比香港更明察秋毫,不畏權貴,尤其是響 transfer pricing 這個避稅大題目上,有時執法及尺度比香港既更嚴,響內地開過廠,或沾手過中港貿易的一定吃過佢地不少苦頭。

內地稅制自 08 年已採用美國 tax resident 這概念,一旦跳入 tax resident 這無間地獄,你 / 你的法人之全球收入,除非兩地已互簽稅務協議,會被徵稅。內地稅制之複雜程度及執法者的嚴謹已與美國趨同,不得不察。
Thomas說…
With regard to the Withholding Enterprise Tax for China Mobile (00941), I have several opinions.

1. Firstly, l would like to declare that I am a shareholder of China Mobile (00941). I am retired and dividend receipts are my major source of income for my living.

2. Not clear - It is very confusing that Withholding Enterprise Tax would apply to companies incorporated in Hong Kong or so called 'Red Chips'. As far as I understand before (mainly from the newspaper), the Withholding Enterprise Tax should only apply to H-shares which are corporated in PRC. But now if it is applicable to Red Chips, so what are the criterias of companies that need to comply with this law? All Red Chips and what is the definition of Red Chip? All companies with business in China? All companies with main source of income from China and what is the definition of 'main source'? How can a small investor like me can clearly know the company that I invested will need to hold dividend tax for enterprise or not?

If Withholding Enterprise Tax can apply to China Mobile, I think it should be similarly applied to other major Red Chip company such as CNOOC (00883) which ex-Dividend date is 18May2009. But until now, I cannot find any CNOOC company announcement from HKEX. If CNOOC needs to comply with this law, would CNOOC defer the ex-Dividend date as China Mobile? How about other Red Chip companies such as China Everbright (00165) which has already passed the ex-Dividend date? Will the investor receive the dividend money as they expected or 10% less? What about other companies such as GZI REIT (00405) which are non-Red Chips but their major income comes from PRC? There are lots of question pending clarification.

3. No help from Hong Kong related parties - When I first knew this Withholding Enterprise Tax for H-Shares from newspaper last year, I saw comments from newspaper saying that this law is only aiming to hold the dividend tax for companies, not individuals. But because most of small investors placed their stock under Bank accounts or Securities firm which are nominee accounts, and there is no way to tell shares under nominee accounts are belong to enterprises or individuals, so the easy way is to treat all shares under nominee account as Enterprise and dividend tax would be held even the actual shareholder is individual person. If this is the case, I saw no one from Hong Kong related parties (eg. HKEX, CCASS) try to help small individual Hong Kong investors by offering a solution to enhance the existing system to differentiate the corporate shareholder from individual shareholders under the nominee account. This may not be easy and may need co-operation from Banks and Securities firms. But this should be done and this is the Right Way to cater this problem in the long run.

4. Not environmental friendly and step backward - Both TV and newspaper told people that if individual investor want to exempt from the tax, individual investors should withdraw shares from Bank accounts / Securities firm and register the shares under self name. I think this should only be a temporary solution. As our society is becoming more and more electronic and paperless, I think the action of withdrawing PHYSICAL shares from nominee account and registering them under self name is not only wasting lot of manpowers, but also totally not environmental friendly and a major step backward from the idea of paperless trading. How can we claim ourself as a modern Financial Centre if investors are encouraged to hold physical shares?

5. Passive Way of Communication for Company Announcement - From the issue of of 00941, I find that the Company announcement from HKEX web site is a passive way of communication with the investors. Imagine that if 00941 did not suspend trading on 13-May-2009, I think most of the people (including myself) will not notice the Withholding Enterprise Tax announcement until somebody found this out and spread the news around. But this may already too late to take any action. I suggest there should be a news feed (or RSS feed) feature for each stock in HKEX web page and investor can register the news feed for any stock freely. Whenever there is new announcement from the company, the announcement can be 'pushed' to the interested party for their review.
匿名說…
I agree with you, expecially point 4.

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