Hong Kong
Gateway to greater China with a mature banking bench.
Hong Kong is the gateway to greater China with a mature English-common-law legal system, a deep banking bench and a territorial tax system that exempts non-Hong-Kong-source income. For businesses genuinely trading into China, or serving Chinese counterparties from an international base, Hong Kong is unmatched.
The political environment has shifted since 2020, and international perception has followed. For structures with meaningful China exposure the jurisdiction remains the right choice; for structures with none, Singapore is often a better fit.
Where Hong Kong fits
- Operating cos
- Trading
- IP
Banking landscape
Hong Kong banking is deep — HSBC, Standard Chartered, Hang Seng, DBS Hong Kong, Bank of China. Onboarding is stricter than a decade ago; source-of-funds documentation and a clear China-related commercial rationale materially help.
Tax & reporting
16.5% profits tax on Hong Kong-source income; a two-tiered rate of 8.25% applies to the first HKD 2m of profits. Foreign-source income is generally exempt (subject to FSIE — Foreign-Sourced Income Exemption — rules for passive income earned by MNE groups). No VAT, no capital gains tax, no dividend withholding tax.
Substance & register visibility
Substance is required for exemption of foreign-source passive income under FSIE. Trading businesses with genuine Hong Kong operations remain in the territorial system; passive holding structures without substance may face taxation on their passive income.
When to pick this jurisdiction
Pick Hong Kong when the business genuinely operates into China, serves Chinese counterparties, or requires China-adjacent banking depth. Consider Singapore or the UAE where China exposure is limited.
Written up as a comparative shortlist.
Every Hong Kong recommendation is delivered as a comparative memorandum — substance defensibility, banking access, treaty coverage, register visibility, cost to maintain and reputational risk — so the client can see the trade-offs before committing.
Considering Hong Kong? Get a written comparison first.
Answer six questions and a director will come back with a shortlist, indicative costs and banking route.
Questions we hear on every Hong Kong intake.
- Is Hong Kong still a good place to bank?
- For businesses with a clear China-facing rationale, yes. For structures with no China nexus, the enhanced onboarding scrutiny often makes Singapore or the UAE more practical.
- What is FSIE?
- The Foreign-Sourced Income Exemption regime, in force since 2023, requires certain MNE groups to meet economic-substance requirements to benefit from Hong Kong's exemption on foreign-source passive income (dividends, interest, IP income and capital gains).
- Can non-residents own a Hong Kong company?
- Yes. There is no residency requirement for directors or shareholders. A Hong Kong company secretary is required and must be resident.
More APAC jurisdictions & related insights
Every engagement begins with a twenty-minute director-led call. Fixed fees, in writing, before any work begins.