Hong Kong offers a profits tax concession for investment vehicles managed by a single family office. Where the conditions are met, qualifying investment profits of a family-owned investment holding vehicle (FIHV) are taxed at 0%. The regime applies from the 2022/23 year of assessment, and a Bill to broaden it was introduced to the Legislative Council in June 2026.
The FIHV must be at least 95% beneficially owned by one family and managed by an eligible single family office, with qualifying assets of at least HK$240 million across the FIHVs it manages, and each FIHV must meet substantial activities requirements in Hong Kong.
The main conditions (current regime)
| Condition | In brief |
|---|---|
| Family ownership | The FIHV must be at least 95% beneficially owned, directly or indirectly, by one or more members of a single family |
| Eligible single family office | A private company that provides services to the family, is at least 75% beneficially owned by the family (subject to conditions), and is centrally managed and controlled in Hong Kong |
| Minimum asset threshold | Aggregate value of qualifying assets held by the FIHVs managed by the family office of at least HK$240 million |
| Substantial activities in Hong Kong | For each FIHV, at least 2 full-time qualified employees in Hong Kong and at least HK$2 million of operating expenditure in Hong Kong each year (these may be met through the family office) |
| Central management and control | The FIHV must be centrally managed and controlled in Hong Kong |
| Qualifying transactions | The 0% rate applies to profits from qualifying transactions in specified assets (such as securities, shares, debt instruments and fund interests) |
Proposed changes (Bill introduced June 2026)
A Bill to enhance the regime was gazetted on 12 June 2026 and introduced to the Legislative Council on 24 June 2026. As published, it proposes to:
- expand the range of qualifying assets, for example to include interests in non-corporate entities, loans, overseas immovable property, digital assets, insurance-linked securities, precious metals (subject to a cap) and carbon credits;
- remove the distinction between "qualifying" and "incidental" transactions, including the 5% incidental transactions threshold;
- clarify how asset values are measured for the HK$240 million threshold;
- apply the changes retrospectively from the 2025/26 year of assessment once enacted.
Related considerations for families
- Immigration: the New Capital Investment Entrant Scheme can be combined with family office arrangements.
- Succession and governance: family charters, trusts, and the roles of family members in the family office.
- Licensing: a single family office serving only one family is generally outside the licensing regime for asset managers, but arrangements that extend to third parties may require a licence; take legal advice.
- Re-domiciliation: since 2025 Hong Kong has allowed qualifying non-Hong Kong companies to re-domicile here, which some families use to bring existing vehicles to Hong Kong.
- Substance and reporting: FSIE, global minimum tax (for large groups) and the reporting obligations of each entity need to be checked.
This guide is general information, not tax or legal advice. The concession is technical and must be confirmed by a Hong Kong tax adviser and, where relevant, a lawyer.
- Incorporating and administering the family office and FIHV companies, including company secretarial, accounting and payroll.
- Supporting the substance requirements: staffing arrangements, office, expenditure records and board governance in Hong Kong.
- Coordinating with tax advisers and lawyers on eligibility and structure.
- Immigration support for family members and staff.
- MAP Asia Pacific advises families on structure, governance and cross-border planning, and RENT-CFO can provide financial oversight for the family office.
Official references
- Inland Revenue Ordinance (Cap. 112), Schedule 16C and related provisions on family-owned investment holding vehicles
- Inland Revenue Department: tax concessions for family-owned investment holding vehicles, www.ird.gov.hk
- Legislative Council: Bill gazetted 12 June 2026 (status to be confirmed)