Filing Form BIRS17 for qualifying ship managers in Hong Kong
How to file Form BIRS17 for the qualifying ship manager tax concession in Hong Kong, covering eligibility and filing procedures.
BIRS17 at a glance
- Official title
- Qualifying ship manager
- Issued by
- Inland Revenue Department
We link the issuing authority's own index rather than hosting a copy, because the form is revised there and an out-of-date copy is worse than none.
Form BIRS17 Guide for the Qualifying Ship Manager in Hong Kong
Form BIRS17 is the mechanism for a ship manager meeting statutory conditions to claim the profits tax concession under the Inland Revenue Ordinance (Cap. 112). It defines who qualifies, what income is eligible, and how to complete and submit the form.
Eligibility Requirements for a Qualifying Ship Manager
To be a qualifying ship manager, an entity must satisfy conditions in the Inland Revenue Ordinance. The Inland Revenue Department (IRD) examines these criteria:
- The ship manager must be a corporation, partnership or individual carrying on a ship management business in Hong Kong.
- The ship manager must manage one or more qualifying ships. A qualifying ship is a sea-going ship of more than 500 gross tonnes registered in Hong Kong or in a jurisdiction with which Hong Kong has a comprehensive double taxation agreement.
- The ship manager must not be the owner or charterer of the ship it manages. The concession is for managers, not ship-owners or lessors.
- The ship manager must hold a valid certificate of registration as a ship manager issued by the Director of Marine under the Merchant Shipping (Registration) Ordinance (Cap. 415).
- The ship manager must have a permanent establishment in Hong Kong and employ sufficient qualified staff to carry out management functions.
The IRD may request supporting documents, including a certified true copy of the ship manager's registration certificate and evidence of each managed ship's qualifying status.
Ship Manager Tax Concession Scope
The ship manager tax concession applies to qualifying profits from managing qualifying ships. It taxes eligible income at a reduced rate. Specifically:
- The concession applies to profits from providing ship management services to qualifying ships. These services include crew, technical, commercial and administrative management.
- Eligible income is calculated by reference to the tonnage of managed ships, not actual profits. This is the tonnage-based profits tax regime.
- The concession does not apply to income from managing non-qualifying ships or from non-ship management activities.
- The concession is elective. A qualifying ship manager may choose to be taxed under the concession for a year of assessment or remain under normal profits tax rules.
The election, once made, applies for a minimum period of three consecutive years of assessment. The ship manager must notify the IRD in writing to withdraw from the concession.
Form BIRS17 Guide: Completing the Form
This Form BIRS17 guide covers the key sections and required information.
Part 1: Ship Manager Particulars
Provide the ship manager's full name, business registration number, principal place of business address in Hong Kong, and tax file number (if any). If the ship manager is a corporation, include the company registration number.
Part 2: Election for the Concession
Indicate whether the ship manager elects to be taxed under the concession for the relevant year of assessment. The election must be made within the time limit specified in the profits tax return (BIR51 or BIR52) or within such further time as the IRD allows.
Part 3: Details of Managed Ships
List each qualifying ship managed during the year of assessment. For each ship, provide:
- The ship's name and official number.
- The port of registry.
- The gross tonnage.
- The period during which the ship was managed.
- The type of management services provided (crew, technical, commercial or administrative).
The IRD may require a certified true copy of the ship's certificate of registry to verify its qualifying status.
Part 4: Eligible Income Calculation
Calculate the eligible income for the year of assessment using the tonnage-based formula. The formula is set out in the Inland Revenue Ordinance and is based on the net tonnage of each managed ship. The IRD provides a tax computation schedule to assist with this calculation.
Part 5: Supporting Documents
Attach the following documents to the form:
- A certified true copy of the ship manager's registration certificate issued by the Director of Marine.
- A certified true copy of the certificate of registry for each managed ship.
- The financial statements of the ship manager for the year of assessment.
- A tax computation showing the eligible income and the concession claimed.
The financial statements and tax computation must be prepared in accordance with Hong Kong Financial Reporting Standards and the Inland Revenue Ordinance.
Filing Form BIRS17 with the Inland Revenue Department
Form BIRS17 is filed together with the profits tax return (BIR51 for corporations or BIR52 for persons other than corporations). Submit the form and supporting documents through the Business Tax Portal or the Tax Representative Portal.
Electronic Filing Requirements
From the year of assessment 2025-26, relevant entities of in-scope multinational enterprise groups must file profits tax returns electronically. Electronic filers must tag the financial statements and tax computation in iXBRL format. The IRD has stated an intention to reach full electronic filing by 2030.
Filing Deadline
The deadline for filing Form BIRS17 is the same as the deadline for the profits tax return. The IRD issues a notice to file the return, which specifies the due date. Late filing may result in penalties.
After Filing
The IRD will assess the concession claim and issue a notice of assessment. If the claim is accepted, the profits tax liability will be calculated using the tonnage-based formula. If the IRD requires further information, it will issue a letter requesting additional documents.
Record Keeping and Compliance
A qualifying ship manager must retain all records relating to the concession claim for at least seven years after the end of the year of assessment. This includes certified true copies of certificates, financial statements, the tax computation and any correspondence with the IRD.
The IRD may conduct a review or audit of the concession claim. The ship manager must be able to demonstrate that it met the qualifying conditions throughout the year of assessment.
Key Points to Remember
- The concession is elective and applies for a minimum of three consecutive years.
- Eligible income is calculated by reference to tonnage, not actual profits.
- The ship manager must hold a valid registration certificate from the Director of Marine.
- The managed ships must be qualifying ships as defined in the Inland Revenue Ordinance.
- Form BIRS17 is filed with the profits tax return through the Business Tax Portal.
- Electronic filing in iXBRL format is mandatory for in-scope multinational enterprise groups from 2025-26.
For the latest version of Form BIRS17 and the accompanying instructions, refer to the Inland Revenue Department's forms index at https://www.ird.gov.hk/eng/paf/bus.htm.
How to fill out Form BIRS17
Page one of the official form. Every field named below appears on it in the same order.
Part 1 - Applicant’s Particulars
1(a) Name of Applicant
Enter the full legal name of the company or individual applying for approval as a qualifying ship manager. This must match the name on the company’s Certificate of Incorporation (for a corporate applicant) or the individual’s Hong Kong Identity Card (for a natural person).
1(b) Business Registration Number
Provide the 8-digit Business Registration (BR) number as shown on the BR certificate issued by the Inland Revenue Department. Do not include the “BR” prefix.
1(c) Address
State the registered office address (for a company) or the principal place of business (for an individual). This must be a physical address in Hong Kong; a PO Box is not acceptable.
1(d) Telephone Number
Give a direct line or mobile number where the applicant can be reached during business hours.
1(e) Name of Contact Person
Write the name of the person authorised to handle enquiries about this application. This is often the company secretary, finance manager, or the applicant’s tax representative.
1(f) E-mail Address
Provide the e-mail address of the contact person.
Part 2 - Type of Application
2(a) / 2(b) / 2(c) / 2(d)
Tick only one box to indicate the type of application:
- 2(a) First application for approval as a qualifying ship manager.
- 2(b) Application for renewal of approval (if previously approved).
- 2(c) Notification of change in particulars (e.g., address, contact details).
- 2(d) Cessation of qualifying ship management activities - use this to inform the IRD that you no longer carry on the trade or business described in section 2 of the Inland Revenue Ordinance.
Common mistake: Tick only one box. If you tick both “first application” and “renewal”, the form may be rejected.
Part 3 - Qualifying Ship Management Activities
Brief description of the qualifying ship management activities carried on or to be carried on
Describe in plain English the management services you provide in relation to qualifying ships (e.g., crew management, technical management, commercial management). The IRD expects this to match the activities listed in the ship management agreement.
Note on supporting documents: Attach a copy of the ship management agreement (if applicable) and a list of ships under management. If the form does not have a specific attachment box, use a continuation sheet.
Part 4 - Declaration
Signature
The form must be signed by:
- The sole proprietor (if a sole proprietorship).
- All partners (if a partnership).
- A director, the secretary, or an authorised person (if a company).
Name of Signatory
Print the full name of the person signing.
Capacity
State the signatory’s position (e.g., “Director”, “Company Secretary”, “Authorised Person”).
Date
Enter the date of signing in dd/mm/yyyy format. The date must be on or after the date of any supporting document you refer to.
Important: If the signatory is not a director or secretary, you must attach a board resolution authorising them to sign. Failure to do so will delay processing.
Download the current form - always file the version on the issuing authority's site, not a copy.
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