GTC 58 has hit the nail on the head, not only in respect of Canada but also Europe. There never was a need to onshore. The original basings system, where you operated in and out of your preferred port was within the law and onshoring dropped an unecessary can of worms into the lap of a badly advised CX management.
I hope Swire understand this better than CX FOPS did when they set up the whole mess.
HKIRD do not recognise CX basing companies and will be sniffing around for the tax that they should rightfully have been paid before onshoring took place.