Taxation

You are the trading company of toys and import goods from Japan and then export goods to USA.
1. If the contract is negotiated in Hong Kong, all sales are subject to Hong Kong Profit tax.
2. If the purchases contract is negotiated in Hong Kong, all purchases are goods of sales and subject to Hong Kong subject tax.
There are no another ways for your company to minimize the Hong Kong Porfit tax liability except you are trading agent of both parties.

For transaction or business not regarded as carried out or performed in Hong Kong and thus no profits tax is being charged, the following points should be noted
1. The transaction is negotiated and concluded outside Hong Kong.
2. Goods never come to Hong Kong even under a transhipment.
3. All decision making on the transaction and all amendments to the sales contract are all performed outside Hong Kong.
4. Hong Kong is only handling the money-in and money-out funding issue.
5, The abinding law on the contract should perferably not the Hong Kong law.
For more information, please go the web-site below.
http://www.ird.gov.hk/chi/paf/bus_pft_tsp.htm

2007-12-05 21:01:09 補充：
Simply negotiation issue is not the critical factor but have to look at the totality of facts. The recommendation of being trading agent of both parties for this transaction is dangerous. FORM over SUBSTANCE? The IRD web-site is a much informative and with a high authority guidance.