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Two-tiered profits tax rates explained

How the lower tax rate on the first HK$2 million works, who can use it, and the connected entities rule.

By DBMS GlobalLast reviewed: 18 October 2026

The answer first

Hong Kong taxes the first HK$2 million of a corporation's assessable profits at 8.25%, and the remainder at 16.5%. For unincorporated businesses the rates are 7.5% and 15%. The lower rate is not available to every company in a group: only one entity among connected entities can elect to use it.

The election is made in the Profits Tax Return. Tax on profits up to HK$2 million is therefore at most HK$165,000.

At a glance

Corporations
8.25% on the first HK$2 million; 16.5% above
Unincorporated businesses
7.5% on the first HK$2 million; 15% above
Maximum saving
HK$165,000 a year for a corporation
Connected entities
Only one can claim the lower tier

How the calculation works

Assessable profits (HK$)Tax at two-tiered rates (HK$)Tax at 16.5% (HK$)Saving (HK$)
1,000,00082,500165,00082,500
2,000,000165,000330,000165,000
5,000,000165,000 + 495,000 = 660,000825,000165,000

The calculation is shown before any tax reductions announced in the annual Budget.

Connected entities

  • Entities are connected if one controls the other, both are controlled by the same entity, or (for individuals) they are under common control in certain ways.
  • Control generally means holding more than 50% of the issued share capital, voting rights or rights to profits, directly or indirectly.
  • Among connected entities, only one, nominated by the group, can use the two-tiered rates for a year of assessment.
  • Splitting one business across several companies to multiply the lower tier does not work.
Key takeawayIf you own several Hong Kong companies, decide each year which one should claim the lower tier, usually the one with the most assessable profit up to HK$2 million.

Making the election

The election and nomination are made in the Profits Tax Return, which asks whether the company has connected entities. Answer accurately: incorrect claims can be reassessed with penalties.

Please noteThis guide is general information, not tax advice. Group structures can be complex; confirm connected-entity status with your tax adviser.

Worked example: two connected companies

Company ACompany B
Assessable profitsHK$1,500,000HK$3,000,000
If A nominatedHK$123,750 (8.25%)HK$495,000 (16.5%)
If B nominatedHK$247,500 (16.5%)HK$165,000 + HK$165,000 = HK$330,000

Nominating A gives total tax of HK$618,750; nominating B gives HK$577,500. The best choice depends on the figures each year, and the saving is capped at HK$165,000 for the nominated entity.

Self-check: where do you stand?

QuestionWhat to do
Do you or your companies control other Hong Kong entities?List all connected entities
Has the group chosen which entity claims the lower tier?Nominate the most suitable entity each year
Is the connected-entity question answered correctly in returns?Review before filing
Are you planning to split a business across companies?Take advice; it will not multiply the lower tier
How DBMS Global can help
  • Identifying connected entities across your companies.
  • Recommending which entity should claim the lower tier.
  • Preparing Profits Tax Returns with the correct election.

In summary

  • 8.25% on the first HK$2 million, 16.5% above.
  • One entity per connected group.
  • Review the election each year.

Official references

  • Inland Revenue Ordinance (Cap. 112), section 14 and Schedule 8
  • Inland Revenue Department: FAQ on the two-tiered profits tax rates regime, www.ird.gov.hk