The Guardian claims that Mr Gulliver - who has worked outside of Britain for 20 of his 30 years at the firm - is seconded to HSBC Holdings via Dutch-based arm HSBC Asia Holdings, although the group denies this is for tax purposes.
"Every one of our 400-plus international managers has their employment contract held through the same HSBC subsidiary, for administrative convenience," HSBC stated. "There is no tax benefit involved."
Barclays boss Bob Diamond has a similar arrangement, being seconded to the lender through Delaware subsidiary Gracechurch, although it remains unclear whether other senior executives at the company are employed in the same way.
Last month, HSBC insisted it had no intention of relocating its headquarters to Hong Kong, after speculation that it could leave the UK in protest at new regulations.
By Asim Shah