Cayman Islands

Under the current laws of the Cayman Islands, the Group is not subject to tax on its income or capital gains.

Chinese Mainland

Under the PRC Enterprise Income Tax Law (the “EIT Law”), the standard enterprise income tax rate for domestic enterprises and foreign invested enterprises is 25%. In addition, the EIT Law and its implementing rules permit qualified “High and New Technologies Enterprise” (the “HNTE”) to enjoy a reduced 15% EIT income tax rate. The HNTE certificate is effective for a period of three years. Certain Chinese mainland subsidiaries, VIEs and VIEs’ subsidiaries, including Beijing U-Tiger Business, Beijing Yixin, Beijing U-Tiger Network, Hangzhou U-Tiger, Guangzhou U-Tiger and Beijing Xiangshang are qualified HNTEs and enjoy a reduced income tax rate of 15% for the years ended December 31, 2023, 2024 and 2025. An entity could re-apply for the HNTE certificate when the prior certificate expires. Historically, all companies successfully re-applied for the certificates when the prior certificate expired. The Group’s other Chinese mainland subsidiaries are subject to an income tax rate of 25%, according to EIT Law.

New Zealand

The Group’s subsidiaries, TBNZ and TFNZ are located in New Zealand and are subject to an income tax rate of 28% for taxable income earned in New Zealand.

Hong Kong

The Group’s subsidiaries incorporated in Hong Kong are subject to a profits tax rate of 8.25% on total assessable profits up to HK$2,000,000 and 16.5% on any part of assessable profits over HK$2,000,000.

USA

The Group’s subsidiaries incorporated in the USA are subject to a federal income tax rate of 21% for taxable income earned in the USA. Taxable income apportioned to New York, New York City, and New Jersey is also subject to tax at statutory income tax rates of 6.5%, 8.85%, and 11.5%, respectively.

Singapore

The Group’s subsidiaries incorporated in Singapore are subject to an income tax rate of 17% for taxable income earned in Singapore. In particular, Tiger Brokers (Singapore) Pte Ltd has been awarded the Financial Sector Incentive Standard-Tier (FSI-ST) scheme with effect from 1 January 2025 to 31 December 2029. Income and expenses derived from qualifying financial activities is subject to tax at 13.5% concessionary income tax rate.

Australia

The Group’s subsidiaries incorporated in Australia are subject to an income tax rate of 30% for taxable income earned in Australia.

The enterprise income tax law imposes a withholding income tax on dividends distributed by a foreign investment enterprise ("FIE") to its immediate holding company outside of the PRC. According to the arrangement between Chinese mainland and Hong Kong, dividends paid by an FIE in Chinese mainland to its immediate holding company in Hong Kong will be subject to withholding tax at a rate of no more than 5%. Dividends paid from US subsidiaries to their parent company are subject to a US withholding tax at a rate of 30%. Cash dividends paid by a New Zealand incorporated company is subject to 5% withholding under the New Zealand-Singapore Double Tax Agreement.

The Company does not intend to have any of its subsidiaries and VIEs located in jurisdictions that would assess a tax on a distribution distribute any accumulated earnings, but rather expects that such profits will be indefinitely reinvested by such subsidiaries and VIEs for their respective local operations. Accordingly, no liability for withholding tax was recorded as of December 31, 2024 and 2025. Undistributed earnings of such subsidiaries and VIEs amounted to US$214.1 million and US$404.6 million and the unrecognized deferred tax liability related to such earnings amounted to US$23.4 million and US$41.3 million as of December 31, 2024 and December 31, 2025, respectively.

The Group’s subsidiaries and consolidated VIEs located in the Chinese mainland, Hong Kong, New Zealand, the USA, Singapore and other jurisdictions are open to tax examination for the period from its inception until the year ended December 31, 2025.

As of December 31, 2024 and 2025, the Group had net operating loss carryforwards of US$131,416,993 and US$129,741,293, respectively.

As of December 31, 2024 and 2025, the Group had advertising expenses carryforwards of US$3,931,434 and US$3,315,153, respectively, which can be carried forward indefinitely.

As of December 31, 2024 and 2025, the Group had withholding tax credit carryforwards of US$1,013,796 and US$139,758, respectively. The balance as of December 31, 2025 will expire in 2026.

Management assessed the positive and negative evidence in certain entities in Chinese mainland, Hong Kong, the United States, New Zealand and Singapore, and estimated they will have sufficient future taxable income to utilize the existing deferred tax assets. Significant objective positive evidence included the significant growth in customer trading activities in the Singapore entity where net operating loss carryforwards can be carried forward indefinitely, in United States entities where net operating loss carryforwards generated after 2017 can be carried forward indefinitely, in Hong Kong entities where net operating loss carryforwards can be carried forward indefinitely, and net operating loss carryforwards in New Zealand can be carried forward indefinitely. Net operating loss carryforwards can be carried forward 5 years in Chinese mainland except for an entity qualified as “HNTE” which can be carried forward 10 years. The Group has concluded that deferred tax asset recognized for certain entities in Chinese mainland, Hong Kong, the United States, New Zealand and Singapore is more likely than not to be realized.

A valuation allowance is provided against deferred tax assets when the Group determines that it is more-likely-than-not that the deferred tax assets will not be realized in the future. The Group considers positive and negative evidence at each individual tax-paying component to determine whether some portion or all of the deferred tax assets are more-likely-than-not to be realized.

The realizability of deferred tax assets requires significant judgment associated with evaluation of past and projected financial performance which incorporates projections of future taxable income, including forecasted revenues and expenses, by tax-paying component. In assessing the realizability of deferred tax assets, management considered the future taxable earnings which consists of forecasted revenue, operating cost and expenses, and the expected timing of the reversal of temporary differences. As of December 31, 2024 and 2025, valuation allowances of US$21,923,356 and US$21,316,154, respectively, were provided against the deferred tax assets that management determined are not more-likely-than-not to be realized in the future. To the extent that actual experience deviates from the assumptions, the projections would be affected and hence management’s assessment of realizability of deferred tax assets may change.

Deferred tax assets related to net operating loss carryforwards without a valuation allowance recognized for the years ended December 31, 2023, 2024 and 2025 were US$1,510,584, US$145,882 and nil, respectively. Due to changes in judgment about the realizability of deferred tax assets, valuation allowance increases of US$3,574,020, US$3,327,769 and nil and valuation allowance decreases of nil, US$1,304,439 and nil were recorded in 2023, 2024 and 2025, respectively. The Group realized a benefit of utilizing deferred tax assets of US$187,483, US$1,295,241 and US$1,343,434 in 2023, 2024 and 2025 that were offset with a valuation allowance at the beginning of the year.