Loretta, works as a vice president in sales of a Hong Kong company. Recently, she was approached by a head-hunter to work for a group of companies. She would be appointed as a director and a brand manager of a company which is resident outside Hong Kong. Her remuneration will be $800,000 per year in total, which may be received in form of directors fee and salary. While she needs to travel outside Hong Kong regularly, she will also spend substantial time working in Hong Kong.

Advise Loretta on how she may split her total remuneration from the new engagement in term of directors fee and salary in order to reduce her salaries tax liability in Hong Kong. You may ignore her tax liability outside Hong Kong.