Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
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HONG KONG DRUG LICENSING

Hong Kong Drug Licence FAQs

Search 500 Hong Kong drug licence FAQs on applications, personnel, premises, quality systems, ongoing regulation, renewals and acquisitions.

Information status: The original FAQ material dates from 2025 and is provided for topic-based reference; it does not represent an individual verification of all 500 FAQs against current rules. For application, fee, renewal, change, product or prescription requirements, please refer to the current official forms and guidance.

Official information from the Drug Office Official information from the Chinese Medicines Board

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Q281 · 如果我的公司是初创企业,香港政府有没有提供针对药品行业的财务资助或贷款计划?独立链接
To support local SMEs and the development of innovation and technology, the Hong Kong Government has established various funding schemes, some of which may be relevant indirectly to the pharmaceutical sector. For example, the SME Financing Guarantee Scheme (SFGS) may help you obtain a higher loan amount from a commercial bank. If your business involves innovative technology, such as a new medicine delivery system or the use of artificial intelligence for quality control, you could consider applying for a project under the Innovation and Technology Fund (ITF). However, it should be made clear that Hong Kong currently has no direct financial subsidy specifically for ‘setting up a pharmacy or pharmaceutical wholesaler’. These schemes are generally open to a wide range of applicants, and you will need to frame your business as a project that meets the relevant eligibility criteria.

📘 Regulatory basis

Different government departments or statutory bodies administer the various government funding schemes. For example, the Hong Kong Mortgage Corporation Insurance Limited (HKMCIC) is responsible for the SFGS, while the Innovation and Technology Commission (ITC) administers the ITF. Each scheme has its own application guidelines and assessment criteria.

📗 Drew Tang's recommendations

Government funding schemes generally take a long time to process, and success rates vary. We do not recommend relying on government funding as your main source of start-up capital. A more practical approach is to treat funding applications as a supplementary financial strategy once your core funding is in place, for specific projects such as technology upgrades or market expansion.

📕 Risk notice

Do not distort your core business model to meet the requirements of a funding scheme. Preparing documents for an application takes considerable time and effort; if the application is ultimately unsuccessful, you will incur opportunity costs. In addition, approved funding is usually earmarked for specified purposes and is subject to strict monitoring and audit, leaving limited flexibility in how it can be used.

Q282 · 在做财务预测时,我应该如何设定一个实际的药品销售毛利率?独立链接
Setting a realistic gross profit margin for medicine sales is central to financial forecasting. This rate varies widely in the pharmaceutical sector, depending on your business type and product mix. Wholesalers or pharmacies dealing in patented and branded medicines may achieve higher margins of 15% to 30% because of brand premiums. Margins may be lower, at 5% to 15%, for generic medicines or ordinary health products in highly competitive markets. Margins may be higher for proprietary Chinese medicines, particularly products with exclusive formulations. A practical approach is to review the financial performance of comparable competitors in the market (if they are listed companies) and set a rate based on this together with your procurement costs and pricing strategy.

📘 Regulatory basis

Hong Kong is a free market, and the Government does not directly regulate medicine prices or gross profit margins. However, your pricing practices must still comply with the Competition Ordinance (Cap. 619), which prohibits collusion with other competitors to fix prices and abuse of a substantial degree of market power.

📗 Drew Tang's recommendations

We recommend that you take a conservative approach to financial projections. You could initially set a relatively low gross margin target and conduct sensitivity analysis to test the company’s profitability and cash flow at different gross margin levels. Once the business is stable, gradually improve the gross margin by optimising procurement and increasing the added value of your services.

📕 Risk notice

Overly optimistic gross margin forecasts are a common reason for business plans to fail. They directly lead to overestimated revenue and underestimated costs, ultimately creating a serious funding shortfall. You must account for real-world factors such as market competition, customers’ bargaining power and potential pressure to reduce prices.

Q283 · 我的药房需要安装一套POS和库存管理系统,这部分的预算应该怎么规划?独立链接
When budgeting for a pharmacy point-of-sale (POS) and inventory management system, several aspects need to be considered: 1. “Software licence fees”: these may be paid as an annual subscription (SaaS model) or as a one-off purchase. For a small or medium-sized pharmacy, the annual subscription may range from several thousand to 20,000 HKD. 2. “Hardware costs”: including cash registers, barcode scanners, receipt printers, and computers and servers for back-office management. This may require a one-off investment of 10,000 to 50,000 HKD. 3. “Implementation and training fees”: the software supplier may charge an initial fee for system installation, data import and staff training. 4. “Ongoing maintenance fees”: under a perpetual licence model, an annual maintenance fee of 15-20% of the total software price is usually payable for technical support and software updates.

📘 Regulatory basis

The Code of Practice for Authorised Sellers of Poisons requires pharmacies to keep detailed records of the receipt and issue of all medicines, including batch numbers and expiry dates. A good computerised system is the best tool for meeting this requirement and can effectively prevent errors and omissions in handwritten records.

📗 Drew Tang's recommendations

Price should not be the only consideration when choosing a system. Give priority to suppliers with many pharmacy clients in Hong Kong, a good understanding of local regulatory requirements and the ability to provide local technical support. The operational efficiency gains and compliance assurance provided by a stable, reliable system are worth far more than its cost.

📕 Risk notice

Choosing an incomplete or unstable system to save money is a major risk. Frequent system outages, data loss or an inability to generate reports that meet regulatory requirements can disrupt your daily operations and may even constitute a serious non-compliance issue during a Department of Health inspection. This is a classic case of ‘penny wise, pound foolish’.

Q284 · 如果我的药品批发业务需要冷链运输(Cold Chain Logistics),这会增加多少成本?独立链接
Cold-chain transport is the most costly part of pharmaceutical logistics and can significantly increase your operating expenses. The additional costs are mainly as follows: 1. “Specialist transport vehicles”: you will need dedicated vehicles fitted with refrigeration units and temperature and humidity data loggers. Their purchase and maintenance costs are far higher than those of ordinary lorries. 2. “Validation and calibration”: refrigerated vehicles and cold-chain facilities in warehouses require regular temperature mapping and equipment calibration. 3. “Packaging materials”: validated shippers and coolants must be used; these are consumables. 4. “Higher transport charges”: if you outsource to a third-party logistics company, cold-chain services typically cost 50% to 200% more than ordinary freight transport.

📘 Regulatory basis

The PIC/S GMP Guide and the Department of Health's Guidance Notes on Licensing of Drug Wholesalers impose stringent requirements on the storage and transport of medicines requiring temperature control, such as vaccines and biological products, including uninterrupted temperature records throughout the supply chain.

📗 Drew Tang's recommendations

For start-ups with low business volumes, we do not recommend setting up your own cold chain fleet. A more cost-effective and efficient approach is to work with one or two reputable specialist third-party cold chain logistics companies with GDP certification. This converts high fixed-asset investment into variable operating costs, reducing initial financial pressure.

📕 Risk notice

Any interruption in the cold chain (Temperature Excursion) may result in the destruction of an entire batch of high-value medicines, causing substantial financial losses. More seriously, if the issue is not detected promptly and the medicines are sold, patient safety may be threatened, leading to serious legal and reputational risks. There must be no compromise in cold-chain management.

Q285 · 我是否需要为我的药品业务购买商业保险?主要应覆盖哪些方面?独立链接
Yes, purchasing comprehensive commercial insurance for your medicine business is an essential risk-management measure. You should focus on the following types of insurance: 1. “Public Liability Insurance”, which provides cover for compensation claims for third-party personal injury or property damage arising from your business activities (for example, a customer slipping in your shop). 2. “Product Liability Insurance”, which is of central importance and covers compensation claims for injury to users caused by defects in products you sell. 3. “Property All Risks Insurance”, which covers your assets, such as your shop, warehouse, equipment and inventory, against losses caused by events such as fire, theft and flooding. 4. “Employees' Compensation Insurance”, which is compulsory by law and is commonly known as employees' compensation insurance.

📘 Regulatory basis

The Employees' Compensation Ordinance (Cap. 282) requires all employers to take out employees' compensation insurance for their employees. Although other types of insurance are not compulsory, the Department of Health may consider whether a licence holder is “fit and proper” by taking account of the adequacy of its risk management measures. Taking out insurance is an important part of this.

📗 Drew Tang's recommendations

Insurance is fundamentally about transferring risk. We strongly recommend working with a professional insurance broker who can tailor a comprehensive insurance plan to your specific business (wholesale, retail or manufacturing) and product risks (high-risk biological products or low-risk health supplements). Premiums should be regarded as a key investment in business continuity.

📕 Risk notice

Trying to “save” on insurance is an extremely dangerous short-sighted approach. A serious product liability claim could amount to millions or even tens of millions of Hong Kong dollars, enough to bankrupt any uninsured SME instantly. You could lose not only your business, but potentially all your personal assets.

Q286 · 如果我的业务失败,需要清盘关闭公司,这过程会产生哪些费用?独立链接
If the business unfortunately fails and the company has to be wound up, the process itself will also incur a range of costs. The main costs include: 1. “Liquidator’s fees”: you will need to appoint a practising accountant or lawyer as liquidator to handle all the company’s outstanding affairs, and their professional service fees will be a major expense. 2. “Asset disposal costs”: appraisals and commissions may be incurred when liquidating stock and selling assets such as shelving and equipment. 3. “Severance payments”: under the Employment Ordinance, you will need to pay severance pay or long service payments to eligible employees. 4. “Government fees”: fees for filing various documents with the Companies Registry. 5. “Legal and accounting fees”: professional fees for handling debts, tax clearance and other matters. The process may take several months, and costs may reach tens of thousands to hundreds of thousands of Hong Kong dollars.

📘 Regulatory basis

The Companies (Winding Up and Miscellaneous Provisions) Ordinance (Cap. 32) of Hong Kong prescribes the legal procedures for winding up a company. The liquidator’s primary duty is to repay the company’s debts in the statutory order of priority, including government taxes and employees’ wages, before ordinary creditors.

📗 Drew Tang's recommendations

One of the main advantages of operating as a limited company is “limited liability”, meaning that shareholders’ liability is limited to the amount of their investment. If the company becomes insolvent, your personal assets will generally not be affected, unless you have given a personal guarantee. This is an important reason why we recommend from the outset that clients operate through a company.

📕 Risk notice

Company directors remain legally responsible during the winding-up process. If misconduct is discovered, such as maliciously transferring assets when the company is close to insolvency or engaging in fraudulent trading, directors may be held personally liable and may even be disqualified from acting as directors in future. Ensure that the entire winding-up process is lawful and compliant.

Q287 · 在财务上,如何区分“资本开支”(CAPEX)和“运营开支”(OPEX)?这对我的税务有何影响?独立链接
In financial and tax planning, it is crucial to distinguish correctly between “capital expenditure” (Capital Expenditure, CAPEX) and “operating expenditure” (Operating Expenditure, OPEX). CAPEX refers to long-term investments to acquire or improve fixed assets, such as purchasing property, carrying out major renovations or buying expensive production equipment. These expenses cannot be deducted in full in the year incurred; instead, they are deducted over the asset's useful life through annual “depreciation” or “allowances”. OPEX refers to expenses incurred to maintain day-to-day operations, such as staff salaries, rent, utilities and medicine purchasing costs. These expenses can be deducted in full from assessable profits in the year of assessment in which they are incurred.

📘 Regulatory basis

Sections 16 and 17 of Hong Kong’s Inland Revenue Ordinance define which expenses are deductible and which are not. The tax treatment of capital expenditure is governed mainly by provisions such as section 34 (industrial building allowances) and section 39E (depreciation allowances for machinery and industrial plant).

📗 Drew Tang's recommendations

This distinction directly affects your tax burden. Incorrectly capitalising operating expenses will overstate your assessable profits for the year and result in overpayment of profits tax. Conversely, claiming capital expenditure as a one-off deduction for operating expenses may be regarded by the Inland Revenue Department as improper tax avoidance. We recommend engaging a professional accountant to ensure that every expense is accounted for and treated correctly for tax purposes.

📕 Risk notice

The Inland Revenue Department has strict guidelines and case law on the distinction between capital and operating expenditure. If you lack adequate legal grounds for the treatment of any significant expenditure in your tax return, you may trigger a Tax Audit. If your treatment is found to be incorrect, you may have to pay the tax due and interest, and may also face penalties.

Q288 · 我计划同时经营西药批发和中成药批发,是否需要为这两个业务设立独立的财务账目?独立链接
Although the law does not require separate legal entities or bank accounts for different business lines within the same company, from a management and compliance perspective we strongly recommend setting up separate “cost centres” or “profit centres” in your accounting system for wholesale of western medicines and wholesale of proprietary Chinese medicines. This means you should be able to track and distinguish clearly the sales revenue, procurement costs, inventory value and related operating expenses for each. This gives you a more detailed management perspective and allows you to assess the profitability of each business area accurately.

📘 Regulatory basis

Western medicines and Chinese medicines are regulated by the Drug Office, Department of Health and the Chinese Medicine Council of Hong Kong respectively, under different regulatory frameworks (Cap. 138 vs Cap. 549). Providing clear, separate business records during inspections by the respective regulatory authorities is an important part of demonstrating compliant operations.

📗 Drew Tang's recommendations

Clear separation of accounts can help you make better-informed business decisions. For example, if you find that the profit margin for your proprietary Chinese medicine business is far higher than that for your Western medicine business, you may decide to allocate more resources to the former, or vice versa. Without separate accounting, all your financial data is a muddle and cannot be analysed effectively.

📕 Risk notice

If accounts are unclear or mixed together, a serious compliance issue in one business segment (for example, the discovery of illegally imported Western medicines) may affect your company’s entire licensing eligibility, including its otherwise compliant Chinese medicine business. Financial segregation can provide a firewall to some extent and reduce the likelihood of risk spreading.

Q289 · 药品库存是我的重要资产,在财务上应该如何进行估值?这对我的财务报表有何影响?独立链接
Medicine inventory is usually classified as “inventory” in the financial statements and is an important current asset. Under Hong Kong accounting standards, inventory should be valued at the lower of cost and net realisable value. “Cost” usually refers to your purchase cost and may be calculated using the first-in, first-out (FIFO) or weighted average cost method. “Net realisable value” is the estimated selling price less the related costs of sale. If, for reasons such as medicines nearing expiry or falling market prices, net realisable value falls below your purchase cost, you must make an inventory write-down provision and recognise the loss in the current income statement, thereby reducing your reported profit and asset value.

📘 Regulatory basis

Hong Kong Accounting Standard 2 – Inventories (HKAS 2), issued by the Hong Kong Institute of Certified Public Accountants (HKICPA), sets out detailed requirements for accounting for inventories, including the components of cost, methods of calculating cost and the determination of net realisable value.

📗 Drew Tang's recommendations

We recommend that you establish a strict stock monitoring system and review the expiry dates and market conditions of all medicines in stock regularly (at least quarterly). For medicines approaching expiry (for example, within 6 months), take action early, such as offering promotions, to avoid their ultimately becoming expired products with no value. Proactive stock management is key to reducing impairment losses.

📕 Risk notice

Overstating inventory value is a common form of financial fraud. If an audit or regulatory inspection finds a substantial discrepancy between the book value of your inventory and the results of the physical stocktake, or that you have failed to make adequate impairment provisions for expired or slow-moving medicines, this may be regarded as seriously misleading financial reporting. It can damage the company’s credibility and may lead to legal consequences.

Q290 · 作为公司董事,我是否需要为公司的债务承担个人责任?在财务上如何规避这种风险?独立链接
In Hong Kong, the main advantage of operating as a “limited company” is the shareholders’ “limited liability”. In ordinary circumstances, as a company director or shareholder, you are not personally liable for repayment of the company’s debts. The company’s creditors can claim only against the company itself, and your loss is limited to the share capital you have invested. However, this protection is not absolute. If you are required to provide a “personal guarantee” when applying for a bank loan or other credit for the company, the bank will be entitled to claim the debt from you personally if the company is unable to repay it.

📘 Regulatory basis

The Companies Ordinance (Cap. 622) establishes the separate legal personality of a limited company and the principle of limited liability for shareholders. However, the Companies (Winding Up and Miscellaneous Provisions) Ordinance also provides that, in certain circumstances such as fraudulent trading, the “corporate veil” may be pierced and directors may be held personally liable.

📗 Drew Tang's recommendations

The best ways to reduce personal liability risks are: 1. Operate as a limited company. 2. Make every effort to avoid giving personal guarantees in business activities. 3. As a director, always act with integrity, prudence and due diligence, and do not engage in conduct that may be regarded as fraudulent or improper. 4. Take out directors’ and officers’ liability insurance (D&O insurance) to cover claims arising from inadvertent errors in the course of performing your duties.

📕 Risk notice

Signing a personal guarantee is a very serious decision; do not do so lightly. Before signing any personal guarantee document, you must fully understand the legal consequences and seek independent legal advice. Once you sign, you are tying your personal assets and financial position to the company’s fortunes, and the protection of limited liability will no longer apply.

Q291 · 在进行财务规划时,我应该如何考虑“通货膨胀”对长期运营成本的影响?独立链接
When undertaking long-term financial planning (for example, over 3 to 5 years), you must consider the impact of inflation; otherwise, your budget will soon become disconnected from reality. Inflation pushes up operating costs across the board, including staff salaries (employees will seek increases to offset the rising cost of living), rent (landlords may raise it on renewal), utility bills and the cost of some locally sourced materials. A simple and effective approach is to set a reasonable annual growth rate for operating expenses in your financial forecast for each future year, for example, by reference to Hong Kong’s average inflation rate over the past few years (usually around 2–3%), and increase the figures accordingly.

📘 Regulatory basis

Although no regulation directly requires you to include inflation in your budget, a robust, forward-looking financial plan is one of the implicit standards regulators use to assess whether you are a “fit and proper” licence holder and whether the company can “continue operating”.

📗 Drew Tang's recommendations

In addition to considering inflation on the cost side, you should also consider it on the revenue side. Does your pricing strategy have enough flexibility to adjust in response to rising costs? We recommend reviewing your pricing structure regularly to ensure that inflation does not continue to erode your profit margins.

📕 Risk notice

Ignoring the impact of inflation can lead to a substantial overestimate of your long-term profit projections. A business plan that appears profitable in its first year may be loss-making three to five years later as costs continue to rise. This is particularly risky for businesses that require long-term investment before returns are realised, such as pharmaceutical research and development.

Q292 · 如果我的药品业务涉及跨境电商,其收款和结汇过程会产生哪些额外费用?独立链接
Selling medicines overseas through cross-border e-commerce platforms involves a range of additional payment collection and foreign exchange conversion costs not found in traditional trade. These costs mainly include: 1. ‘Payment gateway fees’: international payment services such as Stripe and PayPal charge a percentage of the transaction amount (typically around 2.9% plus a fixed fee). 2. ‘Platform commission’: if you sell through a third-party e-commerce platform such as Amazon or Tmall Global, the platform takes 5% to 15% of sales as commission. 3. ‘Currency conversion fees’: banks or payment platforms charge a conversion spread or fee when converting foreign currency sales proceeds into Hong Kong dollars. 4. ‘Withdrawal fees’: a fixed fee may apply when withdrawing funds from a payment platform account to your Hong Kong bank account.

📘 Regulatory basis

Medicines that you sell through cross-border e-commerce must still comply with the import and medicine regulatory laws of the destination country or region. In addition, your receipt of payments must comply with Hong Kong’s anti-money laundering (AML) and counter-financing of terrorism (CFT) requirements, and you must ensure that the source of funds is legitimate.

📗 Drew Tang's recommendations

When setting a pricing strategy for cross-border e-commerce, all the transaction costs mentioned above must be calculated accurately. We recommend preparing a detailed cost analysis table that takes every potential expense into account, to ensure your final prices cover all costs and generate a reasonable profit.

📕 Risk notice

The greatest financial risk is underestimating these “fragmented” transaction costs. Each cost may seem small, but together they can eat into most of your profits. In addition, refund and consumer protection policies in different countries and regions can be very strict, while high return rates can lead to additional logistics and inventory losses.

Q293 · 我应该如何设定我的药品零售价格?是成本加成法定价好,还是参考市场定价好?独立链接
Setting retail prices for medicines is a complex decision that involves balancing multiple factors; there is no single “best” method. Common strategies include: 1. Cost-plus pricing, which adds a fixed gross margin to your purchase cost. This approach is simple and straightforward, and ensures each transaction makes a profit, but may not maximise profits. 2. Market-oriented pricing, which takes as a reference the prices charged by your main competitors for the same medicine. This approach ensures that your prices are competitive, but if your costs are higher than theirs, it may result in slim margins or even losses. A mature pricing strategy generally combines the two approaches and adjusts prices according to different product characteristics, such as exclusivity and brand recognition.

📘 Regulatory basis

Although there is no pharmaceutical price control in Hong Kong, the Competition Ordinance prohibits anti-competitive conduct such as “price fixing”. When referring to market prices, you must make independent decisions and must not agree standard prices with other pharmacies or suppliers.

📗 Drew Tang's recommendations

We recommend that you adopt value-based pricing. In addition to costs and competition, consider the unique value you can offer customers, such as professional advice on medicines, a convenient location and a comfortable shopping environment. These added-value benefits can support setting a price slightly above that of competitors and thereby achieve higher profits.

📕 Risk notice

Although pricing too low may attract customers in the short term, it is dangerous over the long term. It can damage your profitability and trigger a destructive price war, ultimately harming the health of the industry as a whole. Prices that are too low may also make consumers question the source and quality of your medicines.

Q294 · 我的公司需要进行年度审计,聘请会计师事务所的费用大概是多少?独立链接
In Hong Kong, the fees charged by a practising accountancy firm for a company’s annual audit mainly depend on the scale of its business and the complexity of its transactions. For a small or medium-sized pharmaceutical wholesaler or retailer with annual turnover of several million Hong Kong dollars and a simple business model, the annual audit fee is usually between HK$8,000 and HK$20,000. If your company is larger, with annual turnover reaching tens of millions of Hong Kong dollars, or engages in complex international trade or transactions in multiple currencies, the audit fee may rise to tens of thousands or even more than HK$100,000. The fee usually also includes preparing and submitting your profits tax return.

📘 Regulatory basis

Under section 429 of the Hong Kong Companies Ordinance, unless a company is dormant, the annual financial statements of every limited company registered in Hong Kong must be audited by an independent Hong Kong practising accountant.

📗 Drew Tang's recommendations

When choosing an accountancy firm, do not focus on price alone. You should choose a firm with some understanding of the pharmaceutical industry, a good reputation and effective communication. A good auditor should be more than someone who “checks the books”; they should also be your business adviser, helping identify potential risks from a financial perspective and suggest improvements.

📕 Risk notice

Failure to complete the annual audit and submit the tax return on time may result in fines from the Inland Revenue Department and the Companies Registry. Continued non-compliance may lead to prosecution of company directors. In addition, an audit report issued by an unknown or poorly regarded firm will carry much less credibility and may be an obstacle when you need to apply for a bank loan or attract investors.

Q295 · 在财务上,我应该如何规划和管理公司的现金流?为什么它比利润更重要?独立链接
Cash flow planning and management are the lifeblood of a business and are even more important than profit. A company can make no profit in the short term, but without cash for even one day it may fail. Effective cash flow management includes: 1. Preparing a cash flow forecast to estimate monthly cash inflows (such as sales receipts) and outflows (such as rent, salaries and payments for goods) over the next 6 to 12 months, so that future funding gaps can be anticipated. 2. Accelerating collection of receivables to recover payments from customers promptly. 3. Managing payables by making reasonable use of credit terms without damaging supplier relationships. 4. Maintaining a healthy cash reserve by keeping enough cash in the bank to cover 3 to 6 months of operating costs and meet unexpected events.

📘 Regulatory basis

Although no regulation directly prescribes a company’s cash flow level, persistent cash flow difficulties may prevent you from paying staff wages or statutory amounts, such as MPF contributions and tax, on time, thereby breaching the Employment Ordinance or the Inland Revenue Ordinance.

📗 Drew Tang's recommendations

“Profit is an opinion, cash is a fact.” Profit in financial statements includes many accounting estimates (such as depreciation), whereas the cash in your bank account is the real resource available for use. We strongly recommend making cash flow management a core agenda item at your monthly management meetings, and keeping a close eye on the health of the company’s “lifeblood”.

📕 Risk notice

The most dangerous situation is “profitable insolvency”: the company is profitable on paper, but so much cash is tied up in receivables and inventory that it cannot pay debts as they fall due, ultimately triggering a liquidity crisis and collapse. This is particularly common in rapidly expanding businesses.

Q296 · 如果我的药房接受医疗券或保险公司的直接结算,这在财务处理上有什么需要注意的?独立链接
Accepting health vouchers or offering direct settlement with insurance companies can be a good way to attract customers, but particular care is needed in financial administration: 1. “Increased accounts receivable”: unlike cash transactions, you need to submit claims to the government (the health voucher scheme) or insurance companies to receive payment. This process usually takes several weeks or even months and ties up cash flow. 2. “Additional administrative work”: you need dedicated staff to process and reconcile these claims, ensure they are accurate and track payment progress. 3. “Potential bad-debt risk”: some claims may not be recovered if the documents submitted do not meet requirements or there is a dispute over the terms with the insurance company. You should set up a dedicated subsidiary ledger for these receivables in your accounting system.

📘 Regulatory basis

Healthcare service providers participating in the Elderly Health Care Voucher Scheme must comply with the relevant rules and audit requirements set by the Department of Health. Improper use of, or fraud involving, health care vouchers is a serious criminal offence.

📗 Drew Tang's recommendations

Before deciding whether to join these schemes, you must carefully assess their impact on your cash flow. We recommend starting by working with one or two large, reputable insurance companies, then gradually expanding the scope of cooperation once you are familiar with the process and have assessed the administrative costs. Ensure that your POS system can support this complex settlement method.

📕 Risk notice

If you rely too heavily on this business model, where payments are not settled immediately, without sufficient cash-flow reserves, your pharmacy may face liquidity problems. You must strike a healthy balance between the additional sales generated by attracting customers and the cash-flow pressure caused by delayed receipts.

Q297 · 在香港,药品经营企业处置过期或不合格药品,其相关的财务成本和程序是怎样的?独立链接
In Hong Kong, the disposal of expired or non-conforming medicines is a strictly regulated process that incurs costs. These medicines must be handled as “chemical waste” by a waste collector holding a specific licence issued by the Environmental Protection Department (EPD). The main costs are: 1. “Collection and transport fees”: the waste collector will charge according to the weight or volume of the waste. 2. “Treatment fees”: depending on the chemical properties of the medicines, special methods such as incineration may be required, at a higher cost. 3. “Administrative costs”: staff time is needed to segregate and record the waste and arrange its disposal. In the financial statements, the book value of medicines written off in this way must be fully written off as an operating loss for the current period.

📘 Regulatory basis

Under the Waste Disposal (Chemical Waste) (General) Regulation (Cap. 354C), anyone who produces chemical waste must register as a “chemical waste producer” and appoint a licensed collector to dispose of the waste in accordance with Environmental Protection Department requirements. Improper disposal is a criminal offence.

📗 Drew Tang's recommendations

We recommend that you enter into a long-term service contract with a reputable licensed chemical waste collector. At the same time, establish a clear internal medicines destruction SOP (Standard Operating Procedure) to ensure that every step, from identification and segregation to recording and final handover, is documented for inspection by the Department of Health or Environmental Protection Department.

📕 Risk notice

Carelessly discarding expired medicines is extremely dangerous and irresponsible. If discovered, you may not only face prosecution by the Environmental Protection Department and substantial fines, but may also have your licence revoked by the Department of Health for breaching medicines regulations. The price of this kind of ‘saving’ is one you cannot afford to pay.

Q298 · 如果我计划未来将公司出售或寻求上市,在财务规划上需要从早期就注意哪些方面?独立链接
If you have a long-term exit plan, such as being acquired or listing through an IPO, you must plan and manage your finances to the highest standards from the first day the company is established. Key points include: 1. “Clear and orderly accounts”: appoint a reputable accounting firm to ensure that every account is clear, compliant and able to withstand the most rigorous due diligence. 2. “Sound internal controls”: establish and enforce strict internal control procedures covering procurement, sales, inventory, financial approvals and all other areas. 3. “Impeccable compliance record”: maintain a clean record in all areas, including tax, employment and pharmaceutical regulation, with no material breaches. 4. “Clear shareholding structure”: avoid complex, opaque shareholding arrangements.

📘 Regulatory basis

Whether it is the buyer's lawyer in an acquisition or the sponsor and HKEX in an IPO, they will conduct extremely detailed due diligence on the target company's financial and compliance status. Any deficiency could become an obstacle to the transaction or even cause it to fail.

📗 Drew Tang's recommendations

We recommend that you “begin with the end in mind” from the outset. Even if your business is currently small, you should hold yourself to the standards of a company preparing for a public listing. Sound financial and governance structures are not just for a future exit; they also support the healthy development of your current business and risk control. This is an investment that can deliver long-term returns.

📕 Risk notice

If, in the early stages of the company’s development, there are numerous off-the-books transactions, tax irregularities or unclear related-party transactions, these “historical sins” will become major obstacles when seeking an exit in the future. Resolving these historical issues can be extremely costly or even impossible, ultimately causing you to miss the best time to exit.

Q299 · 在制定年度预算时,我应该采用“增量预算”还是“零基预算”的方法?独立链接
When preparing an annual budget, you can choose from different approaches. The most common are incremental budgeting and zero-based budgeting. Incremental budgeting makes small adjustments to the previous year’s budget or actual expenditure based on expected changes, such as inflation or business growth. It is simple and quick, and suits established businesses with stable business models and little change in their operating environment. Zero-Based Budgeting (ZBB) requires every department or item of expenditure to start from “zero” in each new budget cycle and justify its necessity and reasonableness again. This approach is more complex and time-consuming, but can effectively prevent waste of resources and is suitable for companies requiring in-depth cost control or business restructuring.

📘 Regulatory basis

The law does not prescribe the budgeting method a business must use. Whatever method is adopted, the final budget should ensure that the company has sufficient resources to meet all its statutory obligations, including compliance, tax and labour responsibilities.

📗 Drew Tang's recommendations

For start-up pharmaceutical companies, we recommend adopting a “zero-based budgeting” approach in the first year and carefully justifying every item of expenditure. Once the business is stable, you can switch to “incremental budgeting” to improve efficiency. However, we recommend conducting a thorough “zero-based budgeting” review every three to five years to reassess the justification for all expenditure and prevent organisational rigidity and budgetary slack.

📕 Risk notice

The main risk of relying on incremental budgeting over the long term is that it may conceal deep-rooted inefficiencies and encourage the mindset that “if it was done this way last year, it should be done the same way this year”. The budget ceases to be a tool for optimising resource allocation and becomes merely a numbers game, gradually eroding the company’s competitiveness and profitability.

Q300 · 作为药品公司的创始人,我应该给自己发多少薪水?这在财务和税务上有什么讲究?独立链接
As a founder, setting your own salary requires balancing your personal needs, the company's interests and tax implications. The key is reasonableness. For tax purposes, the salary you pay yourself is treated as an operating expense of the company and may be deducted from assessable profits. However, this deduction is conditional on the salary being “reasonable”, having regard to your responsibilities as a company executive, industry salary levels and the company's ability to pay. If the salary is excessive and far above the market rate, the Inland Revenue Department may challenge its reasonableness and treat the excess as a “disguised dividend”, disallowing it as an expense deduction.

📘 Regulatory basis

Section 16 of the Inland Revenue Ordinance allows deductions for expenses incurred in producing assessable profits, while section 17 provides that expenses not incurred in producing those profits are not deductible. The “reasonableness” of directors’ remuneration is key to determining whether it was wholly “incurred in producing profits”.

📗 Drew Tang's recommendations

During a company's start-up period, we recommend that founders draw a relatively low, ‘token’ salary that covers their basic living expenses, leaving more funds in the company for development. Once the company achieves stable profitability, the salary can be increased to the market level. Another option is a ‘low basic salary plus high performance-based dividends’ structure, closely linking personal returns to company performance. This can also demonstrate your commitment and confidence when raising funds from external investors.

📕 Risk notice

Insisting on paying yourself a high salary despite the company’s cash-flow constraints is extremely damaging to team morale and investor confidence. It sends a dangerous signal to the outside world that you are putting personal interests ahead of the company’s interests. In addition, an unreasonably high remuneration arrangement is a common ‘red flag’ in tax audits and can trigger unnecessary tax disputes.

YOUR NEXT STEP

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang

Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

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