Family Office in Hong Kong: Rules, Costs and Tax in 2026
Hong Kong has no licence or registration regime for single family offices: under the SFC's test, an office that does not carry on a business needs no licence, and asset management provided solely to wholly owned companies of its own group is outside the Type 9 licence. Since 2023 a family-owned investment holding vehicle (FIHV) can pay 0% profits tax on qualifying income if its eligible single family office manages at least HK$240 million of specified assets for the family. A Deloitte study for InvestHK counted over 3,380 single family offices at the end of 2025, up from about 2,700 at the end of 2023. [1, 2, 3, 4, 5]
Best for: Families with at least HK$240 million in investment assets who want an Asian common-law base, a single family office that generally needs no SFC licence, 0% profits tax on qualifying investment income and no estate duty.
At a glance
| Licence | Generally no SFC licence if run at cost; Type 9 excludes serving only wholly owned group firms |
|---|---|
| Minimum wealth | None for the SFO; HK$240 million in specified assets for the 0% FIHV tax rate |
| Who counts as family | SFC: no definition. FIHV tax: ancestors, descendants, siblings and spouses; 95% family-owned |
| Serving several families | SFC licence likely needed, commonly Types 1, 4 and 9; FIHV concession not extended to MFOs |
| Law and courts | Common law under the Basic Law; Court of Final Appeal with overseas common law judges |
| Substance | Company: HK office and secretary; FIHV: 2 full-time staff, HK$2 million spending in Hong Kong |
| Holding vehicles | Company, limited partnership fund, open-ended fund company, trust; no foundation law found |
| Corporate tax | Profits tax 8.25% on the first HK$2 million, 16.5% above (2018/19 onwards); territorial |
| Family office tax | 0% for qualifying FIHVs (HK$240 million, 95% family, substance); 2026 bill passage not found |
| Personal income tax | Salaries tax 2% to 17%, capped at 15% on the first HK$5 million and 16% above |
| Inheritance tax | None: estate duty abolished for deaths on or after 11 February 2006 |
| Wills and succession | No forced heirship found; Cap. 73 intestacy rules; dependants may claim provision |
| Residence | New CIES: HK$30 million net assets, HK$30 million invested (HK$3 million in CIES portfolio) |
| Time to set up | Company online usually within 1 hour (4 working days on paper); no official FIHV time |
| Official fees | Company HK$1,545 online, HK$2,350 business registration (1 year, 2026/27); no SFO licence fee |
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Licence and who qualifies
How is a family office licensed in Hong Kong?
There is no dedicated family office licence or registration; a family office is usually a private company. Under the Securities and Futures Ordinance a licence is needed only if the office provides a regulated activity, carries on a business of doing so, and does so in Hong Kong; the SFC says an office paid only reimbursement of its operating costs and not pursuing profit would generally not be carrying on a business, and the Type 9 (asset management) definition excludes services provided solely to wholly owned group companies, including where the top company is wholly owned by the trustee of a family trust. For the FIHV tax concession, the office must be an 'eligible single family office': a private company normally managed or controlled in Hong Kong, at least 95% owned by the family, earning at least 75% of its assessable profits from services to the family and its vehicles, and managing no more than 50 FIHVs. [1, 2, 3, 4]
What is the minimum wealth for a family office in Hong Kong?
No minimum wealth applies to a single family office as such: the SFC licensing test depends on the activity, whether it is a business and where it is carried on, not on wealth. The 0% FIHV tax rate needs an aggregate net asset value of at least HK$240 million in specified assets (Schedule 16C) held by the family's FIHVs and managed by the eligible single family office, tested at the end of each basis period; a shortfall is allowed if the threshold was met at the end of either of the two previous basis periods. [1, 2, 3]
Who counts as family?
The SFC has not defined 'family' or 'family office', and licensing does not depend on whether clients are family members; a single family office may also serve non-family members without a licence if the licensing test is not met. For the FIHV tax concession, family members are a person (living or deceased), the spouse, the lineal ancestors of both, the person's lineal descendants (including adopted and stepchildren), the siblings of the person, spouse and ancestors and their descendants, and the spouses of these descendants and siblings. Family members must hold at least 95% of the FIHV (a tax-exempt charity may hold up to 25% if family members hold at least 75%), and a former spouse remains a family member for the year the marriage ends and the next year. [1, 2, 3]
Can one office serve several families?
The SFC says a multi-family office serves more than one wealthy family, is typically run as a commercial venture and is likely to need an SFC licence before providing services in Hong Kong; such offices commonly hold Type 1 (dealing in securities), Type 4 (advising on securities) and Type 9 (asset management) licences, with Type 2 or Type 5 if futures are involved. Sharing investment staff, research or processes between families may turn an arrangement into a multi-family office. In July 2025 the Government said the FIHV tax concession does not cover FIHVs managed by multi-family offices and that extending it would need a critical look at its effectiveness and fiscal implications. [1, 2, 5]
Law, substance and vehicles
Which law and courts apply?
Hong Kong's constitutional framework is the Basic Law, and its legal system is based on the common law: laws in force include the common law, rules of equity and other laws in force before 1997, laws passed by the Hong Kong legislature and national laws listed in Annex III to the Basic Law, and the NPC Standing Committee has the power to interpret the Basic Law. The Court of Final Appeal, the final appellate court since 1 July 1997, has non-permanent judges from other common law jurisdictions, and courts may use Chinese, English or both. Hong Kong courts may refer to precedents of other common law jurisdictions. [7, 8]
What substance is required?
A private company needs a registered office in Hong Kong, at least one director who is a natural person (no residence rule) and a company secretary who lives in Hong Kong or, if a company, has its office there; no further staff or spending rule for a single family office was found. For the 0% FIHV rate, core income-generating activities must be carried out in Hong Kong with at least 2 qualified full-time employees and at least HK$2 million of operating expenditure in Hong Kong, commensurate with the level of activity; they may be outsourced to the eligible single family office. The FIHV must also be normally managed or controlled in Hong Kong. [3, 9]
Which holding vehicles are available?
Private company limited by shares; limited partnership fund registered with the Companies Registry under the Limited Partnership Fund Ordinance; open-ended fund company (a corporate fund registered with the SFC, regime in force since 30 July 2018); and trusts, with perpetual trusts allowed since 1 December 2013; a Hong Kong company that is not a private company can register as a trust company under Part 8 of the Trustee Ordinance (Cap. 29). An FIHV can be a company, partnership or trust (including a discretionary trust). No Hong Kong foundations law was found in the official sources checked. [3, 9, 10, 11, 12, 13]
Tax
What is the corporate tax rate?
Profits tax applies only to profits arising in or derived from Hong Kong from a trade, profession or business carried on there; profits from selling capital assets are excluded, and dividends from Hong Kong profits-tax-paying companies are not taxed again. Corporations pay 8.25% on the first HK$2 million of assessable profits and 16.5% above, for 2018/19 onwards, but only one entity in a group of connected entities can elect the lower tier. Under the foreign-sourced income exemption (FSIE) regime from 1 January 2023, foreign-sourced dividends, interest, disposal gains and IP income of members of multinational groups can be taxed when received in Hong Kong, unless an exception applies. [14, 15]
Are there tax incentives for family offices?
Under the Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance 2023 (in effect 19 May 2023, for years of assessment from 1 April 2022), qualifying income of an FIHV and its family-owned special purpose entities (FSPEs) is taxed at 0%. Main conditions: at least 95% family ownership, management by an eligible single family office, normal management or control in Hong Kong, at least HK$240 million of specified assets (such as securities, private company shares, futures, foreign exchange contracts, deposits, exchange-traded commodities, foreign currencies and OTC derivatives), 2 qualified full-time employees and HK$2 million of operating expenditure in Hong Kong, and incidental transactions of no more than 5% of trading receipts; the election is irrevocable. A bill gazetted on 12 June 2026 (first reading 24 June 2026) would widen qualifying investments (the 2026 Budget named digital assets, precious metals and specified commodities), remove the 5% limit and exempt all profits of FSPEs, for years of assessment from 2025/26, but no official notice of its passage was found by 19 October 2026. [3, 16, 17, 18, 19, 20]
Is there personal income tax?
Salaries tax is charged at 2%, 6%, 10%, 14% and 17% on successive bands of net chargeable income, but the tax cannot exceed the standard rate on net income: from 2024/25, 15% on the first HK$5 million and 16% on the remainder (a flat 15% until 2023/24). The IRD guide describes no general tax on individuals' dividends or a separate capital gains tax, and interest on deposits with Hong Kong authorised institutions is exempt. [15, 21]
Is there inheritance or estate tax?
No estate duty: the Revenue (Abolition of Estate Duty) Ordinance 2005 abolished it for deaths on or after 11 February 2006. The IRD sources checked mention no separate gift or wealth tax. [6, 15]
Succession and residence
How do wills and succession work?
No forced heirship rule was found: a Hong Kong government leaflet says there is no limitation on what can be included in a will, which under the Wills Ordinance (Cap. 30) must be in writing, signed by a testator aged at least 18 (or married) and witnessed by two people present together. Without a will, the Intestates' Estates Ordinance (Cap. 73) applies; CLIC (University of Hong Kong) says a spouse with children takes the personal chattels, HK$500,000 and half of the rest, the children sharing the other half, and that a spouse, child or dependant can ask the court for reasonable provision under the Inheritance (Provision for Family and Dependants) Ordinance (Cap. 481) within 6 months of the grant. The Trust Law (Amendment) Ordinance 2013 (from 1 December 2013) abolished the rule against perpetuities and added a rule meant to let settlors, especially from civil law countries, set up Hong Kong trusts without heirs later reclaiming the assets under forced heirship rules. [12, 22, 23, 24]
Can the family get residence?
The New Capital Investment Entrant Scheme (New CIES, launched 1 March 2024) needs net assets of at least HK$30 million held for the six months before applying and HK$30 million invested: at least HK$27 million in permissible financial assets and/or Hong Kong real estate (real estate capped at HK$15 million, residential at HK$10 million and only for a single property of at least HK$30 million) plus HK$3 million in the CIES Investment Portfolio run by the Hong Kong Investment Corporation. Since 1 March 2025, investments through an eligible private company wholly owned by the applicant and managed by an eligible single family office can count. A spouse or civil partner and unmarried dependent children under 18 can join; stay is granted for up to 24 months, then extensions of up to three years, and after seven years of continuous ordinary residence a person may apply for the right of abode. [5, 25, 26, 27]
Time and fees
How long does set-up take?
Indicative (Companies Registry and SFC, checked 19 October 2026): a private company limited by shares filed online normally gets its certificate of incorporation within 1 hour, or within 4 working days on paper; a limited partnership fund is normally registered within 4 working days; and the SFC generally approves a private open-ended fund company in under one month after taking up the application. A single family office needs no SFC licence or registration as such, and no official processing time for FIHV advance rulings or New CIES applications was found. [1, 9, 10, 11, 27]
What are the official fees?
Indicative, Companies Registry Price Guide (May 2025): HK$1,545 to incorporate a local company with share capital online (HK$1,720 on paper), plus the business registration fee and levy paid with the application (IRD table: HK$2,350 for a one-year certificate starting between 1 April 2026 and 31 March 2027, being a HK$2,200 fee and a HK$150 levy), and HK$105 for a private company's annual return filed on time. A limited partnership fund costs HK$2,555 plus a HK$479 lodgement fee (December 2023), and a private open-ended fund company pays the SFC HK$5,000 for a single fund (HK$10,000 for an umbrella fund plus HK$1,250 per sub-fund; SFC page of April 2025). No licence fee applies to a single family office that needs no SFC licence; New CIES fees are in a separate Immigration Department fee table that was not opened. [9, 10, 11, 27, 28, 29]
Pros and cons
Pros
- No dedicated licence or registration for single family offices: one run at cost generally needs no SFC licence, and Type 9 excludes asset management solely for wholly owned group companies.
- 0% profits tax on qualifying FIHV income, profits from selling capital assets excluded from profits tax, and no estate duty since 11 February 2006.
- Common law system with a Court of Final Appeal that includes judges from other common law jurisdictions, and perpetual trusts allowed since 2013.
Cons
- The 0% FIHV rate needs HK$240 million in specified assets, 95% family ownership, 2 qualified full-time employees and HK$2 million of operating expenditure in Hong Kong.
- The family office company itself pays profits tax on its fees (8.25% on the first HK$2 million, 16.5% above); the FIHV concession does not cover multi-family offices.
- Wider FIHV qualifying investments (such as digital assets and precious metals) and removal of the 5% limit depend on a 2026 bill with no official notice of passage by 19 October 2026.