The Hong Kong Family Office Tax Concession 2026: the FIHV Regime, Schedule 16E and the 2026 Bill

A family investment vehicle in Hong Kong is charged to profits tax at 0% where it is managed by an eligible single family office and the aggregate net asset value under that office’s management is at least HK$240,000,000. The legal basis is Schedule 16E to the Inland Revenue Ordinance (Cap. 112), inserted by Ord. No. 8 of 2023 and applying from the year of assessment commencing 1 April 2022. This is not an automatic exemption. It requires an irrevocable written election, annual satisfaction of quantitative thresholds, and at least two qualified full-time employees in Hong Kong.

⚠️ Three features change the analysis and almost never appear in summaries of this regime. One: the statutory numbers are floors, not the test. Section 10(1) of Schedule 16E requires the employee count and the expenditure figure to be “adequate in the opinion of the Commissioner” and “in any event” not less than 2 and not less than HK$2,000,000. Meeting the minimum does not mean passing. Two: the family office itself pays tax. Section 2(2)(c)(ii) of Schedule 16E requires the office’s service fees to be chargeable to profits tax under section 14 of the Ordinance. The 0% rate goes to the asset-holding vehicle, never to the office. Three: the HK$240,000,000 threshold and the 0% rate can both be changed without an Ordinance. Section 40AW of Cap. 112 empowers the Secretary for Financial Services and the Treasury, by notice in the Gazette, to amend the employee number, the money amounts, and the rates in sections 24(2) and 25(2) of Schedule 16E.

This analysis states the position as at August 2026. It describes the law in force — Schedule 16E at its point in time of 6 June 2025 — and treats the 2026 Bill separately, because as at the date of publication that Bill has not been enacted.

The Legal Framework: Four Layers and Six Supporting Schedules

The FIHV regime rests on one Schedule to the Inland Revenue Ordinance, two sections of the Ordinance itself, and six supporting Schedules. The layers must be kept apart, because they are amended by different means.

Layer 1 — the enacting Ordinance. The Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance 2023 — Ord. No. 8 of 2023 — was passed by the Legislative Council on 10 May 2023 and gazetted and brought into operation on 19 May 2023. Section 7 of that Ordinance inserted Schedule 16E into Cap. 112.

Layer 2 — the sections that carry the Schedule into the Ordinance. These are sections 40AV and 40AW of Cap. 112, which together form Part 6E. Section 40AV(2): “Schedules 16F, 16G, 16H, 16I, 16J and 16K contain provisions supplementary to Schedule 16E.” Section 40AV(3): “Schedules 16E, 16F, 16G, 16H, 16I, 16J and 16K apply in respect of a year of assessment commencing on or after 1 April 2022.”

Layer 3 — Schedule 16E itself. The Schedule as in force carries the cross-reference “[ss. 2, 19CA, 40AV, 40AW & 80 & Schs. 16C, 16F, 16G, 16H, 16I, 16J & 16K]” and the source note “(Amended 21 of 2025 s. 32)”. It runs to six Parts and 29 sections.

Layer 4 — the six supporting Schedules. Schedules 16F to 16K, added by the same Ord. No. 8 of 2023, carry the machinery for computing beneficial interests and deemed assessable profits. Their point in time remains 19 May 2023; none has been amended since.

Schedule	What it governs	Cross-reference from Schedule 16E
Schedule 16C	The eleven classes of assets whose trans­actions attract the concession	section 9(3)(a)
Schedule 16E	The FIHV and FSPE regime itself	—
Schedule 16F	Extent of a family member’s beneficial interest in an entity	section 8
Schedule 16G	Extent of an unrelated natural person’s beneficial interest	section 8
Schedule 16H	Extent of one entity’s beneficial interest in another	sections 8 and 20
Schedule 16I	Extent of an FIHV’s beneficial interest in an FSPE	sections 11 and 16
Schedule 16J	Computing a resident person’s assessable profits under section 22	section 22
Schedule 16K	Computing a resident person’s assessable profits under section 23	section 23

The point in time of Schedule 16E as in force is 6 June 2025. The amending instrument is Ord. No. 21 of 2025, section 32. The precision matters: section 32 of that Ordinance is headed “Consequential amendments to cross-references in various Schedules”, so the change is referential rather than substantive — none of the regime’s conditions was rewritten. The significance lies elsewhere: since 6 June 2025 Schedule 16E has sat formally inside the global minimum tax perimeter created by the same Ordinance.

Layer 5 — what does not yet exist. The Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026 was gazetted on 12 June 2026 and received its first reading on 24 June 2026. As at 12 August 2026 it remains unenacted: the Government confirms it “is currently under scrutiny by the LegCo’s Bills Committee, with the clause-by-clause examination completed”, and that resumption of the second reading debate is targeted for the second half of 2026.

Sitting alongside the statute is a layer of administrative practice — and here there is a gap. The Inland Revenue Department has issued no DIPN on the FIHV regime. The Departmental Interpretation and Practice Notes run to No. 63 (November 2023) and none addresses Schedule 16E. Author’s assessment: this is a conspicuous omission, because during the passage of the 2022 Bill the Administration expressly told the Bills Committee that a DIPN would be issued on enactment. More than three years later, it has not been. What stands in its place is the IRD’s own page “Tax Concessions for Family-owned Investment Holding Vehicles” — which refers the reader to DIPN 31, “Advance Rulings” — and the advance ruling mechanism itself. The published ruling series now runs to No. 78, but only Ruling No. 73 of 17 January 2024 addresses Schedule 16E: Rulings 74 to 78 concern other provisions, including the FSIE regime, corporate treasury centres and ship leasing.

A note on source access. The consolidated text of Cap. 112 on elegislation.gov.hk is closed to automated retrieval but opens in a browser session; every provision of Schedule 16E, Schedules 16F to 16K and sections 40AV and 40AW cited here has been checked against that consolidated text. The 2026 Bill on legco.gov.hk remained inaccessible; it is described from the Government’s own press releases and, where separately flagged, from large international firm alerts with the level of confirmation stated expressly.

FIHV and ESF Office: Two Entities, Two Different Tax Outcomes

The FIHV holds the family’s assets and gets the 0% rate; the ESF Office manages them and pays profits tax at the ordinary rate. Conflating the two is the most common structural error in this area.

The FIHV definition — section 5(1) of Schedule 16E. An entity (Entity A), “whether established or created (however described) in or outside Hong Kong”, is a family-owned investment holding vehicle for a year of assessment if:

•          at all times during the basis period, one or more members of a particular family hold at least 95% in aggregate of the beneficial interest, whether direct or indirect, in Entity A; and

•          Entity A is not a business undertaking for general commercial or industrial purposes as mentioned in section 20AM(6) of the Ordinance.

The point most often reported incorrectly: an FIHV need not be a Hong Kong entity. The statute expressly contemplates a vehicle established outside Hong Kong. The Hong Kong nexus appears elsewhere — in section 9(4)(a), which requires the FIHV to be “normally managed or controlled in Hong Kong” during the basis period. That is a management test, not an incorporation test.

“Entity” is wider than “company”. Section 1 of Schedule 16E defines an entity as “a body of persons (corporate or unincorporate) or a legal arrangement” and includes a corporation, a partnership and a trust. An FIHV may therefore be a trust or a partnership.

The family office definition — section 2(1) of Schedule 16E. A private company is a family office if:

•          the company is “normally managed or controlled in Hong Kong”; and

•          the company provides services to specified persons of a family.

Here the form requirement is rigid: only a private company qualifies. A trust or a partnership cannot be a family office for Schedule 16E purposes. The asymmetry is real and worth naming: the FIHV may be any entity in any jurisdiction, while the family office must be a Hong Kong private company.

The ESF Office definition — section 2(2) of Schedule 16E. A family office is an eligible single family office of a particular family for a year of assessment where three conditions hold together:

•          (a) at all times during the basis period, one or more members of the family hold at least 95% in aggregate of the beneficial interest, direct or indirect, in the office;

•          (b) the office satisfies the safe harbour rule in section 3 of Schedule 16E;

•          (c) the office provides services to specified persons of the family during the basis period, and — sub-subparagraph (ii) — “the fees for the provision of those services are chargeable to profits tax under section 14 for that year”.

Paragraph (c)(ii) is the price of the regime, and it is rarely priced in. The family office must be a Hong Kong profits tax payer on its own fee income, at the ordinary two-tiered rates of 8.25% on the first HK$2,000,000 of assessable profits and 16.5% above that. So the FIHV regime does not zero-rate the whole structure — it moves the taxing point from the assets to the management fee. The larger the office’s fee, the more tax is paid inside the arrangement.

The two entities compared:

Feature	FIHV (section 5)	ESF Office (section 2)
Legal form	Any entity: corporation, partner­ship, trust, other arrangement	Private company only
Place of establish­ment	Hong Kong or outside Hong Kong	Not prescribed, but manage­ment and control must be in Hong Kong
Hong Kong nexus	“Normally managed or controlled in Hong Kong” — section 9(4)(a)	“Normally managed or controlled in Hong Kong” — section 2(1)(a)
Family holding	At least 95% (relieved to 75% in defined circum­stances)	At least 95% (relieved to 75% in defined circum­stances)
Profits tax rate	0% — section 24(2)	8.25% / 16.5% — ordinary rates, section 14
Numerical cap	50 FIHVs may elect through one office — section 14(3)	One office per FIHV — section 14(1)(b)
Election	Mandatory and irrevocable — section 14	Not applicable
Employee require­ment	Two or more qualified employees — section 10(1)(b)	No separate require­ment; the office’s staff may satisfy the FIHV’s test

One FIHV, one office. Section 14(1)(b) denies the concession unless the FIHV is managed by only one ESF Office of its family. The constraint in the other direction is different in kind: section 14(3) permits up to 50 FIHVs to elect through a single office.

The FSPE — section 6 of Schedule 16E. A family-owned special purpose entity is the vehicle through which an FIHV holds investments; its profits from the same qualifying transactions are charged at 0% under section 25(2). Section 6 also introduces the IFSPE — the interposed family-owned special purpose entity — sitting between the FIHV and the ultimate FSPE in a chain.

Because an FIHV may be established outside Hong Kong yet must be managed and controlled from Hong Kong, families with an existing offshore vehicle regularly ask whether to move it. The general company re-domiciliation regime is analysed in Company Re-domiciliation to Hong Kong in 2026.

Who Counts as “Family” — and Why Hong Kong’s Definition Is Unusually Wide

Section 4 of Schedule 16E builds the family around a single natural person and imposes no generational limit at all.This is one of the few parameters on which the Hong Kong regime is objectively more permissive than Singapore’s, and for a multi-generational family with broad collateral branches it is not a technicality.

The construction — section 4(1). A natural person — “whether alive or deceased” — is designated Person A. Person A and all persons related to Person A together constitute a family, and each of them is a member of the family.

Who is related — section 4(2):

Label	Who this is	Provision
Person B	A spouse of Person A, including a deceased spouse	section 4(2)(a)
Person C	Any lineal ancestor of Person A	section 4(2)(b)(i)
Person D	Any lineal ancestor of Person B	section 4(2)(b)(ii)
Person E	Any lineal descendant of Person A	section 4(2)(b)(iii)
Person F	A sibling of Person A, B, C or D	section 4(2)(b)(iv)
Person G	Any lineal descendant of Person F	section 4(2)(b)(v)
—	A spouse, including a deceased spouse, of Person E, F or G	section 4(2)(c)

Section 4 contains no generational cap. Subsection (3) defines descent and ascent recursively: a child of a natural person (Child A) is a lineal descendant; a child of Child A (Child B), a child of Child B, “and so on”, equally so. The same recursion applies upwards through Parent A, Parent B, “and so on”.

The practical reach is far wider than “children and grandchildren”. Because siblings of the lineal ancestors of both Person A and Person B are included — that is, the uncles and aunts of both spouses — together with all their lineal descendants without limit, a Hong Kong “family” can run to several hundred individuals across five or six generations on both sides.

The definition of “child” in section 4(4) is deliberately generous: a child of the person or of that person’s spouse (including a deceased spouse) or former spouse, “whether or not the child was born in wedlock”, and including an adopted child or step child of either of them.

Set against Singapore, this is a genuine Hong Kong advantage. Under the single family office licensing exemption framework of the Monetary Authority of Singapore, which took effect on 15 June 2026, a “single family” means all lineal descendants of a common ancestor no more than five generations removed, together with current and former spouses, adopted children, stepchildren, parents-in-law and siblings-in-law. Hong Kong imposes no generational limit whatever. For a family whose wealth has already passed through four generations, that single difference determines whether the collateral branches count towards the 95% test or fall out as unrelated persons.

“Specified persons” is the wider concept the office actually serves. The safe harbour rule in section 3 is measured by the share of management profits derived from services to specified persons of the family — a class broader than the family members themselves, extending to the entities through which the family holds assets, including the FIHVs and FSPEs.

Deceased persons are included on purpose. Person A, the spouse, and any lineal ancestor or descendant may be deceased. Author’s assessment: the drafting is designed so that a structure built around a first-generation founder does not collapse on the founder’s death — the “family” continues to be defined from the same fixed point. For succession planning that means generational change alone does not push a structure outside the regime. What does is dilution of the family holding below 95%.

The 95% Tests: Two of Them, Two Reliefs, and a Hard 5% Ceiling

There are two separate 95% tests in the FIHV regime — one on the family office, one on the holding vehicle. They sit in different sections of Schedule 16E and each carries its own relieving machinery.

Test one — the family office, section 2(2)(a). At all times during the basis period, one or more members of the family must hold at least 95% in aggregate of the beneficial interest, direct or indirect, in the office.

Test two — the FIHV, section 5(1)(a). At all times during the basis period, one or more members of the family must hold at least 95% in aggregate of the beneficial interest, direct or indirect, in the vehicle itself.

The words “at all times during the basis period” make each test continuous rather than a year-end snapshot. A holding that dips below the threshold for a single day mid-year fails the test for the whole year on the face of the statute.

The relief works identically in both tests and is built as “Condition 1 plus Condition 2” — sections 2(3) to 2(7) for the office, sections 5(2) to 5(6) for the FIHV.

Element	Content	Office	FIHV
Condition 1	Family members hold at least 75% but less than 95% of the beneficial interest	section 2(4)	section 5(3)
Condition 2, first limb	One or more charitable entities hold a beneficial interest	section 2(5)(a)	section 5(4)(a)
Condition 2, second limb	Either no unrelated person holds a beneficial interest, or the total interest of all unrelated persons does not exceed 5%	section 2(5)(b)	section 5(4)(b)
Effect	The 95% test is treated as satisfied	section 2(3)	section 5(2)

The drafting of the effect matters legally. Section 2(3): where both conditions are met, the members of the family “are taken to have” at least 95% in aggregate. This is a deeming provision, not a lower threshold: the test remains a 95% test and is treated as passed.

The 5% ceiling on unrelated persons is absolute, and it is the only one. The relief does not permit a stake to be granted to a partner or a professional manager beyond 5%. An equity incentive scheme giving hired executives more than 5% of the family office destroys ESF Office status outright — and with it the concession for every FIHV under that office’s management, up to fifty of them.

Two anti-circumvention rules sit inside the relief itself.

Section 2(6): an unrelated person is not regarded as holding a beneficial interest in the office where that interest arises only because a charitable entity holds one. A donor or beneficiary of the charity is not automatically swept in.

Section 2(7): in measuring an unrelated person’s interest, any interest that person holds (a) in a charitable entity that holds an interest in the office, or (b) in any other unrelated person that is an entity and holds such an interest, is disregarded. Author’s assessment: section 2(7) prevents double counting, so that a chain of holdings cannot artificially inflate the unrelated-person percentage and defeat the relief.

“Charitable entity” is defined by reference to section 88 of the Ordinance — the same charitable exemption machinery that governs Hong Kong charities generally.

How the percentages are actually computed is not arithmetic but statute. Section 8 of Schedule 16E hands the calculation to three Schedules:

•          Schedule 16F — the extent of a family member’s interest in an entity;

•          Schedule 16G — the extent of an unrelated natural person’s interest;

•          Schedule 16H — the extent of one entity’s interest in another.

Section 7 of Schedule 16E separates direct from indirect beneficial interest. Section 7(4) describes a chain of two or more interposed entities: the particular person holds a direct interest in the first, each interposed entity other than the last holds a direct interest in the next, and the last holds a direct interest in the ultimate person. Section 7(5) strips out shares that carry no right to dividends and no right to a distribution of assets on dissolution other than a return of capital. Section 7(6) confines voting rights to rights exercisable at a general meeting.

> The practical consequence: the 95% test is a look-through test, and it runs through trusts and foundations. In the IRD’s published Advance Ruling Case No. 73 the family held its interest directly and through both a trust and a foundation, and the aggregate 95% was measured on exactly that look-through basis. Designing a structure without running the calculation through Schedules 16F to 16H is designing it blind.

How Much Is Enough: the HK$240,000,000 Threshold and the Specified NAV Rule

The threshold is HK$240,000,000 of aggregate net asset value in Schedule 16C assets managed by the family office, measured at the end of the basis period, with a fallback to either of the two preceding years.

The mechanics are in section 11 of Schedule 16E, headed “Provision supplementary to section 10 of this Schedule—Specified NAV Rule”. The rule is complied with if any one of three Requirements is met.

Requirement	Period tested	Additional condition	Threshold
Requirement 1	End of the basis period for the subject year	None	not less than HK$240,000,000
Requirement 2	End of the basis period for the first preceding year	The office was established in or before that year, andRequirement 1 is not met	not less than HK$240,000,000
Requirement 3	End of the basis period for the second preceding year	The office was established in or before that year, andneither Requirement 1 nor Requirement 2 is met	not less than HK$240,000,000

The statutory formula carries a currency clause: “not less than $240,000,000 (or its equivalent in a foreign currency)”. Foreign-currency assets are translated, not excluded.

Three points determine what actually counts.

First, the test aggregates across vehicles. Section 11(2) sums the NAV of the Schedule 16C assets of each relevant FIHV managed by the office. A family may run up to fifty separate vehicles — by branch, by generation, by asset class — and clear the threshold once, in aggregate.

Second, FSPE assets count proportionately. Section 11(8): a reference to the NAV of an FIHV’s Schedule 16C assets includes the NAV of Schedule 16C assets held by each FSPE in which the FIHV holds a beneficial interest, to the extent of that interest. The extent is computed under Schedule 16I.

Third, the valuation method belongs to the Commissioner. Section 11(7): “the NAV of any Schedule 16C assets is to be determined in the manner specified by the Commissioner”. Valuation is not a matter of taxpayer choice.

The most frequent failure at this threshold is counting the family’s wealth instead of its Schedule 16C assets. Excluded from the count are Hong Kong real estate, operating stakes outside the Schedule 16C classes, art, aircraft, yachts and physical precious metals. A family shown at “around HK$400 million” on a private banking statement may hold HK$150 million of Schedule 16C assets and fail.

Requirements 2 and 3 protect against a market drawdown, not against being small. Both are available only where the office already existed in the relevant preceding year. A newly established office has no look-back and must satisfy Requirement 1 in its first year.

The threshold sets the floor of economic viability. At HK$240,000,000 of assets, the mandatory HK$2,000,000 of Hong Kong expenditure equals 0.83% of assets a year — and that is only the expenditure the statute compels, before professional fees and before stamp duty on the way in. In Advance Ruling Case No. 73 the family office incurred at least HK$10,000,000 a year against assets of “a few billion Hong Kong dollars”, or roughly 0.2% to 0.5%. The economics improve steeply with scale and are marginal at the threshold itself.

The threshold is not a fixed feature of the statute in the ordinary sense. Section 40AW(1)(b) of Cap. 112 names “the amounts specified in sections 10(1)(c)(ii) and 11(2), (4) and (6) of Schedule 16E” among the figures the Secretary for Financial Services and the Treasury may amend by notice in the Gazette. Both HK$240,000,000 and HK$2,000,000 are therefore alterable by subsidiary legislation, without a Bill passing through the Legislative Council.

The 2026 Bill does not abolish the threshold. Neither the Government’s press releases nor the 2026-27 Budget Speech announces any change to the HK$240,000,000 figure. Large international firm alerts — secondary only, not confirmed against the Bill text — report that the Bill changes the measurement basis rather than the amount: from “net asset value” to the value of qualifying investments under management, with loans from holders of direct beneficial interests no longer deducted. If that survives into the enacted text, the threshold becomes marginally easier to clear for structures financed by intra-family debt.

The Substance Requirement: Two Employees, HK$2,000,000, and the Word “Adequate”

The substantial activities requirement has two numerical minimums and one qualitative criterion, and it is the qualitative criterion that decides outcomes.

The text of section 10(1)(b) and (c) of Schedule 16E:

•          (b) the average number of qualified employees during the basis period “(i) is adequate in the opinion of the Commissioner; and (ii) is in any event not less than 2”;

•          (c) the total operating expenditure incurred in Hong Kong for carrying out investment activities during the basis period “(i) is adequate in the opinion of the Commissioner; and (ii) is in any event not less than $2,000,000”.

The formula “adequate in the opinion of the Commissioner; and in any event not less than” makes 2 and HK$2,000,000 floors, not the test. Two employees against a multi-billion-dollar portfolio of derivatives and private transactions is unlikely to be found adequate. No published summary of this regime states the point this directly, and the distinction is fundamental: compliance with the minimum does not equal satisfaction of the requirement.

Who is a “qualified employee” — section 10(2). A person is a qualified employee in relation to an FIHV if:

•          (a) the person is a full-time employee in Hong Kong; and

•          (b) the person (i) carries out investment activities in Hong Kong during the basis period and (ii) has the qualifications necessary for doing so.

All three elements are required at once: full-time, in Hong Kong, and appropriately qualified. A non-resident director attending board meetings is not a qualified employee. Nor is a part-time appointment.

The test is on the average number over the basis period, not the headcount at year end. Hiring two people in December of a December year-end produces no average.

The expenditure must be incurred in Hong Kong and on investment activities. Section 10(1)(c) reads “operating expenditure incurred in Hong Kong for carrying out investment activities”. Spending outside Hong Kong, and spending unconnected with investment activity, does not count.

Outsourcing to the family office is accepted — but as IRD practice, not as statute. The IRD’s page on the regime states: “Outsourcing of CIGAs to the eligible SFO is permitted provided that the use of outsourcing is not for circumventing the substantial activities requirement”, with activities remaining “commensurate with the level of the CIGAs carried out in Hong Kong”. The word “outsourcing” appears nowhere in section 10; its acceptability rests on the Department’s administrative position rather than on the primary text. In practice this means the FIHV need not employ anyone directly — the office’s staff can satisfy the test.

The “subject ESF Office” — section 10(3). In relation to an FIHV for the subject year, this means a family office that (a) is an ESF Office of the family to which the FIHV is related and (b) “on the last day of the basis period, manages the FIHV”. A change of managing office mid-year does not break the regime if the incoming office manages the vehicle on the final day.

What compliance looks like in practice — from Advance Ruling Case No. 73, issued 17 January 2024:

Period	Office	Employees	Annual Hong Kong expendi­ture
1 January to 30 June 2023 (transitional)	Company B	three full-time employees	at least HK$3,000,000
From 1 July 2023 (ongoing)	Company Z	four full-time employees	at least HK$10,000,000

Author’s assessment: Ruling No. 73 is the only public indication of what the Department treats as adequate, and both figures are multiples of the statutory minimum. A family with “a few billion Hong Kong dollars” of assets ran four employees and spent five times the statutory floor. Planning a comparable structure around two employees and HK$2,000,000 is planning a dispute with the Commissioner.

The functions the ruling accepted as the office’s investment activities were: “(i) conducting research and advising on any potential investments to be made by Company X; (ii) acquiring, holding, managing or disposing of property for Company X; and (iii) establishing or administering Company Y for holding and administering one or more underlying investments of Company X”.

The employee number is itself alterable by subsidiary legislation. Section 40AW(1)(a) of Cap. 112 names “the number specified in section 10(1)(b)(ii) of Schedule 16E” among the figures amendable by notice in the Gazette.

The employment-law and payroll consequences of staffing an office in Hong Kong are set out in Payroll and Employer Obligations in Hong Kong 2026 and Hong Kong Salaries Tax 2026: Source of Income and the 60-Day Rule.

The Family Office Safe Harbour: the FOMP Formula and Why the Office Should Hold Nothing

The safe harbour rule requires at least 75% of the family office’s management profits to come from serving its own family. It is measured by profits — not by assets, and not by client numbers.

The provision is section 3 of Schedule 16E, headed “Provision supplementary to section 2 of this Schedule—safe harbour rule”. Section 3(1): the office satisfies the rule for a subject year if it falls either within the 1-year safe harbour under subsection (2) or within the multiple-year safe harbour under subsection (3).

Safe harbour	Condition	Provision
1-year	The office’s FOMP percentage for the subject year is greater than or equal to 75%	section 3(2)
Multiple-year	The average FOMP percentage over the “specified years” is greater than or equal to 75%	section 3(3)

“Specified years” carries two different meanings — section 3(4):

•          (a) where the office has provided services in Hong Kong, to any person or entity, for fewer than two consecutive years of assessment immediately before the subject year: the subject year and the preceding year — two years;

•          (b) where the office has provided services in Hong Kong for two or more consecutive years immediately before the subject year: the subject year and the two preceding years — three years.

The formula — section 3(5):

FOMP percentage = FOMP ÷ P, where FOMP is the aggregate management profits of the office in the basis period derived from services provided to one or more specified persons of the family, and P is the aggregate profits accruing to the office from all sources in that period.

The denominator captures everything, not just management income. “Profits accruing to the family office from all sources” means interest income, gains on the office’s own investments, and any other receipt increases P without adding to FOMP — and therefore reduces the percentage.

The consequence usually missed: parking assets on the family office’s balance sheet is dangerous. An office earning HK$8,000,000 of management fees and HK$4,000,000 of investment income on its own portfolio has a FOMP percentage of 66.7% and fails the 1-year safe harbour — even though it has no third-party clients at all.

Serving other families is permitted, but capped at a quarter of profits. The regime is called a single family office regime, yet the statute does not prohibit outside work; it limits its share. The 25% headroom is a single allowance covering everything: outside clients and the office’s own investment income alike.

The multiple-year safe harbour is a tool for an atypical year, not a standing alternative. It averages over two or three years and absorbs a single distortion — a large one-off mandate for a third party, for instance.

The safe harbour is a condition of ESF Office status, not of the FIHV concession directly. Breach means the office ceases to be an eligible single family office, which in turn causes section 10(1)(a) to fail for every FIHV it manages. A single failure at office level switches off the regime across the whole group of vehicles.

The office’s fee must be at arm’s length. Sections 2 and 3 impose no express arm’s-length requirement, but it arrives from two directions. First, section 2(2)(c)(ii) requires the fee to be chargeable under section 14 of the Ordinance — and related-party pricing is governed by the transfer pricing rules in Part 8AA of Cap. 112. Second, section 26 of Schedule 16E allows the Commissioner to deny the concession where a main purpose of an arrangement is obtaining a tax benefit. Advance Ruling Case No. 73 describes the office’s remuneration expressly as an “arm’s length service fee” — not incidental detail, but a condition on which the ruling was given.

This creates a tension worth modelling in advance. Depressing the office’s fee reduces its profits tax but shrinks the FOMP numerator and pushes the office towards the safe harbour boundary. Inflating it strengthens the safe harbour but increases tax at 16.5%. The optimum is neither the minimum nor the maximum but the market rate that survives transfer pricing scrutiny. The Hong Kong transfer pricing framework — sections 50AAF and 50AAK, and the master and local file thresholds — is analysed in Transfer Pricing in Hong Kong 2026: Part 8AA of Cap. 112.

What Is Actually Exempt: Section 9, Eleven Asset Classes and the 5% Rule

The 0% rate does not apply to all of an FIHV’s profits. It applies to profits from transactions in Schedule 16C assets, and to incidental transactions within a 5% cap measured on trading receipts.

Section 9(2) of Schedule 16E: profits tax is charged “at the rate specified in section 24(2) of this Schedule” on the FIHV’s assessable profits for the basis period earned from the transactions specified in subsection (3), if the condition in subsection (4) is met.

Section 9(3) — two categories:

•          (a) transactions in Schedule 16C assets — qualifying transactions;

•          (b) subject to subsection (5), transactions incidental to the carrying out of qualifying transactions — incidental transactions.

Section 9(4) — a two-limb condition:

•          (a) the FIHV “is normally managed or controlled in Hong Kong” during the basis period; and

•          (b) at all times during the basis period, the FIHV’s qualifying transactions “(i) are carried out in Hong Kong by or through an ESF Office of the family that manages the FIHV; or (ii) are arranged in Hong Kong by such an office”.

Limb (b) requires the office itself to execute or arrange. Investment decisions taken by an external manager outside Hong Kong do not satisfy it.

The eleven Schedule 16C classes — the same list used in the unified funds exemption under sections 20AN and 20AO. The Schedule was added by Ord. No. 5 of 2019, section 11, and amended by Ord. No. 9 of 2021, section 11 and Ord. No. 8 of 2023, section 6; its header cross-reference reads “[ss. 20AM, 20AN, 20AO, 20AP & 20AS & Schs. 16D, 16E & 17A]”. The classes sit in Part 1; the definitions sit in Part 2.

No.	Class of asset under Schedule 16C, as enacted
1	Securi­ties
2	Shares, stocks, deben­tures, loan stocks, funds, bonds or notes of, or issued by, a private company
3	Futures contracts
4	Foreign exchange contracts under which the parties agree to exchange different currencies on a particular date
5	Deposits other than those made by way of a money-lending business
6	Deposits as defined by section 2(1) of the Banking Ordi­nance (Cap. 155), made with a bank as defined by Part 1 of Schedule 1 to the Securi­ties and Futures Ordi­nance (Cap. 571)
7	Certificates of deposit as defined by Part 1 of Schedule 1 to Cap. 571
8	Exchange-traded commodi­ties
9	Foreign currencies
10	OTC deriva­tive products as defined by Part 1 of Schedule 1 to Cap. 571
11	An investee company’s shares co-invested by a partner fund and the ITVFC under the ITVF Scheme

What the list omits is what defines the regime’s edges. Schedule 16C does not include immovable property in any jurisdiction, Hong Kong or otherwise; physical precious metals; art and collectibles; digital assets; insurance-linked instruments; or operating interests in non-corporate structures. Profits from any of these cannot reach the 0% rate.

The 5% rule for incidental transactions — section 9(5) — is measured on receipts, not profits. Subsection (2) does not apply to profits from incidental transactions if the percentage computed as A ÷ B × 100 exceeds 5, where:

A is the FIHV’s trading receipts from incidental transactions in the basis period; B is the total of its trading receipts from qualifying and incidental transactions in that period.

A trading-receipts base is markedly harsher than an assessable-profits base. A low-margin, high-turnover incidental activity can breach 5% on receipts while remaining trivial in profit terms.

Breach is contained. Section 9(5) switches off the 0% rate only for the incidental profits; profits from qualifying transactions remain at 0%.

Section 9(6) subordinates everything to the exceptions: “This section is subject to sections 10, 12, 13 and 14 of this Schedule.”

The rate lives in its own section, and that is not a formality. Section 24(1) states that the section applies for the purposes of section 9(2). Section 24(2): “The rate specified for the basis period for a year of assessment commencing on or after 1 April 2022 is 0%.” Section 25(2) mirrors it for FSPEs. These two subsections, not section 9, contain the zero rate — and they are the ones named in section 40AW(1)(c) as amendable by notice in the Gazette.

Losses are ring-fenced — section 15 of Schedule 16E. Where, because of sections 9 and 24, an FIHV is exempt from profits tax on its profits from section 9(3) transactions, any loss sustained from those transactions is not available for set-off against assessable profits for that year or any subsequent year. Section 19 mirrors this for FSPEs.

Ring-fencing is the price of the zero rate, and it is a real one. A portfolio that loses HK$50,000,000 in year one and makes HK$50,000,000 in year two would pay no tax across the two years under the ordinary regime. Under the FIHV regime the year-one loss is stranded and the year-two profit is charged at 0% — the same outcome, but only because the rate is zero. Should the rate ever be changed under section 40AW, the stranded losses do not come back.

The 2026 Bill proposes to abolish the 5% rule altogether. The Government’s press release of 12 June 2026 lists “removing the 5 per cent threshold requirement for incidental transactions” among the five groups of amendments. That is confirmed at primary level as a statement of Government intent; the corresponding clause text remained inaccessible.

The Four Exceptions: When Section 9 Fails Despite Everything Else Being Right

Section 9 is expressly subject to four exceptions, three of which concern transactions in private company securities. Failure under any one costs either a single transaction or the whole regime.

Exception	Section	What is tested	Consequence of failure
Exception 1	section 10	NAV threshold, employee count, expendi­ture	Section 9 does not apply to the FIHV at all for the year
Exception 2	section 12	Transactions in securities of a private company holdingHong Kong immovable property	Section 9 does not apply to profits from those transactions
Exception 3	section 13	Transactions in securities of a private company not holding Hong Kong immovable property	Section 9 does not apply to profits from those transactions
Exception 4	section 14	Election made, and single managing office	Section 9 does not apply to the FIHV at all

Exception 2 — section 12 — Hong Kong immovable property. The section applies where, during the basis period, an FIHV transacts in specified securities — shares, stocks, debentures, loan stocks, funds, bonds or notes — of a private company (the relevant company), and that company holds, directly or indirectly, (i) immovable property in Hong Kong or (ii) share capital in another private company that holds, directly or indirectly, immovable property in Hong Kong.

The fork is at ten per cent — sections 12(2) and 12(3):

•          where the aggregate value of the immovable property and share capital held by the relevant company exceeds 10%of the value of that company’s assets, section 9 does not apply to the FIHV’s profits from those transactions, with no saving provision at all;

•          where it does not exceed 10%, section 9 does not apply unless the FIHV meets a condition in subsection (4) in good faith.

The conditions in section 12(4) — a holding period test and a short-term asset test:

•          (a) the FIHV disposes of the securities not less than two years after acquiring them, whether or not it has control over the relevant company; or

•          (b) the FIHV disposes of them less than two years after acquisition and either (i) the FIHV does not have control over the relevant company, or (ii) where it does have control, the relevant company holds, directly or indirectly, short-term assets whose aggregate value does not exceed 50% of the value of its assets.

The short-term asset threshold in Schedule 16E is 50%, and it is routinely confused with 20%. The 20% figure belongs to a different provision — the parallel test in section 20AQ of the Ordinance under the unified funds exemption. Schedule 16E uses 50%, verified against the consolidated text of the Schedule.

Exception 3 — section 13 — the mirror rule for “clean” companies. It applies where the relevant company holds neither Hong Kong immovable property nor share capital in another private company holding it. Unless the FIHV meets the condition in subsection (3) in good faith — the same two-year holding test with the same control and short-term asset carve-outs — section 9 does not apply to the profits from those transactions.

Read together, sections 12 and 13 mean this: transactions in private company securities are outside the regime by default, and can be brought back in only by holding for two years or by demonstrating absence of control. Rapid turnover of private company stakes does not attract the 0% rate.

Sections 17 and 18 impose mirror exceptions on FSPEs. In Advance Ruling Case No. 73 the material assumptions are stated squarely: Company X “will not fall into the circumstances where the exceptions specified in section 12 or 13 of Schedule 16E” apply, and Company Y likewise for sections 17 and 18. In other words, the Department gave the ruling on the assumption that these tests would not bite, rather than testing them. The exposure remains entirely with the taxpayer.

Hong Kong immovable property held directly by an FIHV is outside Schedule 16C altogether. Rental and trading profits from it are charged at the ordinary rates of 8.25% on the first HK$2,000,000 and 16.5% above. Genuine capital gains are untaxed in any event, since Hong Kong has no capital gains tax. Author’s assessment: holding Hong Kong property inside an FIHV achieves nothing and carries a specific danger — a substantial letting operation invites an argument that the vehicle is a business undertaking for general commercial purposes and so fails section 5(1)(b) outright.

The 2026 Bill does not change the policy direction. Large international firm alerts — secondary only — report that the Bill adds immovable property situated outside Hong Kong to the qualifying classes while preserving the exclusion for income from private companies trading in or developing Hong Kong immovable property. This is not confirmed against the Bill text.

The Election: Irrevocable, Capped at Fifty, and Subject to No Statutory Deadline

The FIHV regime does not apply by default. It requires a written election that can never be withdrawn.

Section 14 of Schedule 16E — Exception 4:

•          Subsection (1): section 9 does not apply to an FIHV unless (a) an election is made in relation to the FIHV under this section and (b) the FIHV is managed by only one ESF Office of its family.

•          Subsection (2): an FIHV managed by an ESF Office of its family — an eligible FIHV — “may in writing elect”that section 9 applies to it.

•          Subsection (3): for each ESF Office of the family, not more than 50 eligible FIHVs managed by that office may make an election.

•          Subsection (4): “An election under this section, once made, is not revocable by the FIHV concerned.”

Three distinct requirements, each capable of destroying the regime on its own.

Form. The election is made in writing. The IRD confirms: “the election must be made in writing”, “the election, once made, will apply to all subsequent years of assessment (i.e. no annual election is required)” and “the election made is irrevocable”. No annual repetition is needed.

A single managing office. Section 14(1)(b) requires management by only one ESF Office. Splitting management of one vehicle between two family offices — by asset class, for instance — destroys the regime for that vehicle.

The cap of fifty. Section 14(3) does not limit how many FIHVs a family may have; it limits how many may elect through a single office. A family needing more than fifty must establish a second ESF Office — and the HK$240,000,000 threshold will then have to be cleared by each office separately, because section 11(2) aggregates only within one office.

Schedule 16E specifies no deadline for the election. Section 14 fixes neither a calendar date nor a link to the return filing deadline. The operative deadline comes from the filing mechanics: the election is made through supplementary form S20 (BIRS20), “Tax concessions for family-owned investment holding vehicle”, lodged with the profits tax return. Form S20 is one of the twenty-two supplementary forms S1 to S22 and must be filed electronically through the Business Tax Portal or the Tax Representative Portal: it is completed offline, exported to XML and uploaded with the e-filed return.

Irrevocability is a standalone risk that has to be assessed before, not after, the election. Two features make it material. First, loss ring-fencing under section 15. While the rate is zero, ring-fencing is harmless. If the rate is ever changed by notice under section 40AW(1)(c), the vehicle finds itself under a non-zero rate with no ability to carry forward historic losses. Second, the global minimum tax. For a family whose group consolidates a substantial operating business and crosses the EUR 750 million revenue threshold, a 0% Hong Kong rate depresses the jurisdictional effective rate and can trigger top-up tax. In that configuration the concession does not save tax — it relocates it, and the election cannot be undone.

Beneficial ownership records — sections 28 and 29 of Schedule 16E.

Section 28(2): a responsible person for an entity that is an FIHV must keep sufficient records enabling the identity and particulars of each beneficial owner to be readily ascertained. Section 28(3): records are kept throughout the period the person remains such an owner. Section 28(4): on cessation, records are retained for at least seven years from the date of cessation. Sections 28(5) and 28(6) extend the duty to the cases where the entity ceases to be an FIHV or ceases to exist — again for seven years. Section 29 imposes the mirror duty on the ESF Office.

Who is a “responsible person” — section 28(7): in relation to an entity that is a corporation, the corporation itself; in relation to any other entity, the person responsible for the management of the entity. “Beneficial owner” covers not only those holding a direct or indirect beneficial interest but also the specified members as defined in section 20(1) of Schedule 16E.

The sanction sits outside Schedule 16E. The Schedule’s cross-reference header names section 80 of Cap. 112, the general offence provision of the Ordinance. The IRD confirms the existence of a penalty — “Penalties will be imposed on the FIHV and the eligible SFO if they fail to comply with the record-keeping requirements without reasonable excuse” — and the 2023 Bills Committee papers identify a fine at level 3.

The parallel beneficial ownership regime under Hong Kong company law is covered in The Significant Controllers Register in Hong Kong, and the wider annual compliance cycle in Mandatory Annual Compliance for Hong Kong Companies 2026.

Anti-Round-Tripping: Why It Misses the Family, and How That Is Engineered

Hong Kong neutralises the anti-round-tripping rule for family structures not by an exemption but by a definition: in Part 4 of Schedule 16E, natural persons are not “resident persons” at all.

The problem the drafters had to solve. Under the unified funds exemption, sections 20AX and 20AY of the Ordinance deem the exempt profits of a fund to be the assessable profits of a Hong Kong resident person holding at least 30% of the beneficial interest — or any interest at all where the fund is that person’s associate. For a Hong Kong family owning its vehicle outright, that destroys the value of the exemption completely. This is why the fund exemption is practically useless to a family, and why a separate regime was needed.

How Schedule 16E solves it — section 20, the definition of “resident person”. Section 20(2) is exhaustive:

•          (a) a corporation that is not a trustee of a trust is a resident person if its central management and control is exercised in Hong Kong in the year of assessment;

•          (b) a partnership that is not a trustee of a trust, on the same basis;

•          (c) a trustee of a trust, where the central management and control of the trust is exercised in Hong Kong.

Natural persons do not appear. For Part 4 purposes a “resident person” can only be a corporation, a partnership or a trustee. Sections 22 and 23 of Schedule 16E therefore cannot, as a matter of law, reach a family member holding an FIHV directly as an individual. This is not a concession or an exemption; it is how the definition is built. Saying “the anti-round-tripping rule does not apply to resident individuals” describes the outcome accurately but hides the mechanism — and hiding the mechanism obscures where the boundary actually runs.

The rule itself, in section 22, is very much alive for entities. Subsection (1): where a resident person holds a beneficial interest in an FIHV to the extent prescribed in subsection (2), and section 9 applies to the FIHV, the FIHV’s assessable profits are regarded as the resident person’s assessable profits arising in or derived from Hong Kong from a trade, profession or business carried on in Hong Kong. Subsection (2) sets the extent at not less than 30% — separately for a corporation, a partnership, a trust and any other entity — counting interests held jointly with any associate, whether or not that associate is a resident person.

Section 22(4) is a second gateway with no threshold at all. Where a resident person holds a beneficial interest in an FIHV of any size and the FIHV is an associate of that person, the profits are attributed. “Associate” for sections 22 and 23 is defined separately in section 21.

Section 22(5): the rule bites regardless of distribution. Subsections (1) and (4) apply irrespective of whether the resident person has received or will receive any money or other property representing the FIHV’s profits.

Section 22(6): control of a trust is treated as 100%. A resident person holding a direct or indirect beneficial interest in a trust because that person is able — or might reasonably be expected to be able — to control the activities of the trust estate or the application of its corpus or income is regarded as interested in 100% of the value of the trust. This is the provision aimed at hollow discretionary trusts with retained control.

Section 22(8) is the carve-out that makes the regime workable. Subsections (1) and (4) do not apply to a resident person who, at all times during the relevant period, is:

•          (a) a specified entity in relation to the family to which the FIHV is related;

•          (b) a trustee of a trust that is such a specified entity; or

•          (c) an ESF Office of the family managing the FIHV.

“Specified entity” — sections 20(3) to 20(7). An entity (Entity C) is a specified entity where either Condition 1 or Condition 2 is met.

Condition	Requirements
Condition 1 — section 20(4)	Entity C (i) is not a business under­taking for general commercial or industrial purpose and (ii) does not carry on any trade or business; and at least one family member holds a direct or indirect beneficial interest in it; and Entity C is the entity, or one of the entities in a chain, through which a family member holds an indirect interest in the FIHV
Condition 2 — section 20(5)	Entity C (i) is not a business under­taking for general commercial or industrial purpose and (ii) does not carry on any trade or business; and Entity C is a qualified entity within section 20(6)

Both conditions share one requirement: the entity must be passive. “Does not carry on any trade or business” excludes any interposed company with operating activity. A family holding company that also runs a trading business falls outside the carve-out — and the FIHV’s profits can then be attributed to it.

Section 22(9) prevents double taxation up the chain. Where a resident person is liable because of an indirect interest held through one or more interposed entities, and any interposed entity is itself a resident person liable under subsection (1) or (4), the upper-tier resident person is discharged from its liability to that extent. The computation of the attributed amount is governed by Schedule 16J for section 22 and Schedule 16K for section 23.

How this played out in practice — Advance Ruling Case No. 73. The parent of the structure was Company W, a Hong Kong-incorporated company and therefore a “resident person” on the face of section 20(2)(a). The Department nonetheless ruled that sections 22 and 23 “will not operate to regard the assessable profits of Company X and Company Y as assessable profits of Company W”. The mechanism is the section 22(8) carve-out: Company W was a passive holding entity through which the family held the FIHV, and so a specified entity under Condition 1. The ruling runs from the year of assessment 2023/24 onwards.

> The design rule that follows: never place a trading entity between the family and the FIHV. A passive holding company is safe. A holding company with an operating function is a direct route to attribution of the FIHV’s profits under section 22.

What the Regime Costs: Mandatory Spend, Stamp Duty and the Break-Even Point

There is no entry fee for the FIHV regime — no application charge, no annual levy. The real cost is the mandatory Hong Kong spend, the stamp duty on funding the structure, and the tax paid by the family office itself.

Component one — mandatory Hong Kong expenditure. Not less than HK$2,000,000 a year and not fewer than twoqualified full-time employees, subject in both cases to the Commissioner’s view of adequacy.

Schedule 16C assets	HK$2,000,000 as a share of assets
HK$240,000,000 (the threshold)	0.83% a year
HK$500,000,000	0.40% a year
HK$1,000,000,000	0.20% a year
HK$3,000,000,000	0.067% a year

Component two — the family office’s own tax. Section 2(2)(c)(ii) requires the office’s fees to be chargeable under section 14 of the Ordinance, at the ordinary two-tiered rates of 8.25% on the first HK$2,000,000 of assessable profits and 16.5% above.

Component three — stamp duty on funding the structure, and this is the most underestimated line.

The rate on transfers of Hong Kong stock is 0.1% per contract note, buyer and seller, so 0.2% in total, plus HK$5 fixed duty on the instrument of transfer. The reduction from 0.13% took effect on 17 November 2023 under the Stamp Duty (Amendment) (Stock Transfers) Ordinance 2023, gazetted 16 November 2023.

A gift is charged differently, and for family structures a gift is the usual case. A transfer by way of voluntary disposition inter vivos attracts HK$5 plus 0.2%, where an ordinary sale attracts 0.1% on each of two contract notes — the same 0.2% in total. Contributing shares to a vehicle for no consideration does not escape the duty.

There is no FIHV-specific stamp duty relief. Schedule 16E is a profits tax regime only, and the IRD’s page on the concession does not mention stamp duty at all.

Section 45 relief under the Stamp Duty Ordinance is narrower than most planning assumes. It applies to transfers of immovable property or shares “from one associated body corporate to another”. The practical consequences:

•          individual to FIHV: no relief. A family member contributing shares in a Hong Kong company to a newly formed vehicle is not a body corporate. On a HK$240,000,000 portfolio of Hong Kong stock that is up to HK$480,000 of duty before the zero rate produces a single dollar of benefit;

•          trustee to FIHV: no relief either, for the same reason;

•          existing holding company to FIHV: section 45 may apply, subject to the association test and the anti-avoidance conditions.

The association test is framed as beneficial ownership of not less than 90% of the issued share capital. This appears on the face of the statutory declaration used to claim the relief, Stamp Office form IRSD124, in which the declarant confirms beneficial ownership of “not less than ninety per cent of the issued share capital”, that the instrument was not executed “in pursuance of or in connection with any such arrangements as are described in section 45(4) or 45(5) of the Ordinance”, and that the transferee intends to continue as beneficial owner after the transfer.

Section 45 relief is available only through adjudication. A Stamp Office circular states the position plainly: even where two companies might be eligible for intra-group relief, an Exchange Participant must collect the duty “as the case had not been submitted to Stamp Office for adjudication”. The relief does not operate automatically; without an application to the Stamp Office the duty is payable.

This is why most working structures are not built on Hong Kong shares. Securities that are not “Hong Kong stock” attract no Hong Kong stamp duty, so contributing an offshore holding company into an FIHV is duty-free while contributing the shares of a Hong Kong operating company is not. The sequence in which a structure is assembled affects total cost more than the choice between an FIHV and an ordinary company does.

Section 45 is proposed to be relaxed, but as at August 2026 the relaxation is not law. The 2026-27 Budget (paragraph 103) proposes “to relax the criteria for stamp duty relief in relation to the intra-group transfer of assets”, expanding the scope of eligible associated bodies corporate. The IRD’s stamp duty page gives the detail: the minimum ownership threshold falls from 90% to 75%, and eligibility extends to bodies without share capital, for instruments executed on or after 25 February 2026. The IRD’s Budget page still lists this among proposed measures, “subject to change during the legislative process”. Neither stamp duty Ordinance passed in 2026 carries it: the Stamp Duty (Amendment) Ordinance 2026, Ord. No. 3 of 2026, effective 29 May 2026 deals with the high-value residential rate, and the Stamp Duty (Amendment) (No. 2) Ordinance 2026, Ord. No. 5 of 2026, effective 17 July 2026 deals with renminbi dual counters.

The Department has already built a bridge for the interim, and it is worth knowing about. The IRD’s own wording is expressly conditional: “Subject to the enactment of the relevant amendment ordinance, if a body corporate has at least 75% of direct or indirect beneficial interest in another body corporate; or a body corporate is entitled to exercise, or control the exercise of, at least 75% of the voting rights in another body corporate, the body corporate will be deemed as having an associating interest in the other body corporate”, extended to “bodies corporate that do not issue or allot share capital such as limited liability partnerships which has separate legal personality”, for instruments executed on or after 25 February 2026. The Department is accepting adjudication requests for instruments meeting the enhanced conditions and holding the decision over until enactment, so the duty need not be paid and later reclaimed. Anyone executing an intra-group transfer today is nonetheless relying on retrospective enactment.

The wider stamp duty mechanics, including net-asset valuation, deadlines and penalties, are set out in Stamp Duty on Share Transfers in Hong Kong 2026.

Component four — what the regime does not cost. No registration fee, no annual regulatory levy, no SFC licence for a family office serving only its own family, and no mandatory external manager.

Break-even is not a question of asset size but of where the profits come from.

The question most models skip: is there any Hong Kong tax to save? Even without any concession, Hong Kong does not tax capital gains, excludes dividends from corporations that have already borne Hong Kong tax, and applies a territorial basis that leaves foreign-sourced profits outside the charge entirely. A family holding a long-term portfolio of foreign equities through an ordinary Hong Kong company already pays close to nothing. How the territorial basis and the offshore claim actually work is set out in The Offshore Profits Claim in Hong Kong. The 0% rate is worth 16.5% of something only where the profits would otherwise be Hong Kong-sourced and revenue in nature — that is, active trading managed from Hong Kong. That is the genuine use case, and it is narrower than the regime’s promotion suggests.

A rough viability check. HK$2,000,000 of mandatory annual expenditure is recovered by tax saved at 16.5% on roughly HK$12,100,000 of Hong Kong-sourced assessable profits a year. A portfolio generating that much Hong Kong-sourced trading profit at a 5% return corresponds to assets of about HK$240,000,000. Author’s assessment: the statutory threshold and the break-even point coincide almost exactly, which suggests HK$240,000,000 was not chosen arbitrarily — it approximates the level below which the mandatory spend consumes the whole benefit.

How the Regime Interacts with FSIE, Pillar Two and the Rest of the Ordinance

The FIHV regime does not sit in isolation. It intersects with the foreign-source income exemption regime, with the global minimum tax, and with the capital gains certainty scheme — and the intersections do not all run the same way.

FSIE: why an FIHV’s profits are not “specified foreign-sourced income”

The FSIE regime — sections 15H to 15N of Cap. 112 — charges certain foreign income received in Hong Kong and, since 1 January 2024, covers disposal gains on property of every kind, not just equity interests.

An FIHV is carved out of FSIE by definition rather than by exception. Section 15H(1), in defining specified foreign-sourced income, excludes at paragraph (b) any interest, dividend or disposal gain that “(i) accrue to an entity the assessable profits of which are chargeable to tax at the rate specified in a concession provision (as defined by section 19CA) other than section 14A(1); and (ii) are derived from, or is incidental to, the activity that produces those assessable profits”.

The link to section 19CA is confirmed on the face of Schedule 16E itself: the Schedule’s header cross-reference reads “[ss. 2, 19CA, 40AV, 40AW & 80 & Schs. 16C, 16F, 16G, 16H, 16I, 16J & 16K]”. Section 19CA defines “concession provision”, and because Schedule 16E charges profits at a rate rather than exempting them, the FIHV travels through paragraph (b) — not paragraph (c), where sections 20AC, 20ACA, 20AN and 20AO are named individually.

Advance Ruling Case No. 73 confirms the outcome on two independent limbs.

•          Limb one, definitional — ruling (e): foreign-sourced interest, dividends and disposal gains derived by Company X as an FIHV and Company Y as an FSPE from their qualifying and incidental transactions to which the concession applies will not be regarded as specified foreign-sourced income under section 15H(1).

•          Limb two, substantive — ruling (f): where such income does fall within the definition, section 15I(1) does not apply because Company X and Company Y each “meets the economic substance requirement under section 15K of the IRO”.

The FSIE limb of that ruling is time-limited to the years of assessment 2023/24 to 2027/28. The FIHV treatment itself runs from 2023/24 onwards without a stated end.

The practical read-across: a structure that satisfies section 10 of Schedule 16E will almost certainly satisfy section 15K. The FSIE test carries no numerical thresholds and turns on the Commissioner’s view of adequacy; the Schedule 16E test applies the same qualitative standard and adds two numerical minimums. Clearing the harder test clears the easier one automatically.

There is also an earlier gate that is frequently missed. FSIE applies only to an “MNE entity” — a person that is, or acts for, an MNE group or an entity in one, where an MNE group includes at least one entity or permanent establishment not located in the jurisdiction of the ultimate parent entity. A purely Hong Kong single-family structure is not an MNE entity, and FSIE simply does not engage. The typical FIHV structure, with offshore FSPEs and offshore investee holdings consolidated under a Hong Kong parent, is another matter.

Pillar Two: why excluded entity status does not rescue a family office

The legal basis is the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 — Ord. No. 21 of 2025 — enacted on 6 June 2025, whose clause 14 added Part 4AA and whose clause 31 added Schedules 61 to 65 to Cap. 112. The threshold is consolidated revenue of EUR 750 million in at least two of the four preceding fiscal years. The income inclusion rule and the Hong Kong minimum top-up tax apply to fiscal years beginning on or after 1 January 2025.

The excluded entity list in Schedule 61 has six categories: a governmental entity; an international organisation; a non-profit organisation; a pension fund; an investment fund that is an ultimate parent entity; and a real estate investment vehicle that is an ultimate parent entity.

Author’s assessment: an FIHV cannot be an “investment fund” for GloBE purposes — and what prevents it is precisely the condition that makes it an FIHV. The GloBE definition of an Investment Fund requires, among other things, that the entity be designed to pool assets from a number of investors, at least some of whom are unconnected. Schedule 16E requires at least 95% of the beneficial interest to be held by members of one family. A vehicle statutorily reserved to a single family does not pool the assets of unconnected investors. The family office is further removed still: it is a service company earning management fees, not a fund of any kind.

The relief that does exist for an FIHV is narrower and different in nature. The IRD states that investment entities and insurance investment entities are excluded from the scope of the HKMTT so as to preserve their tax neutrality.That is not excluded entity status: the vehicle remains a constituent entity of an in-scope group for income inclusion rule purposes, but is carved out of the Hong Kong domestic top-up tax, with its income and taxes excluded from the jurisdictional effective rate computation.

In nearly every case the binding constraint is the revenue threshold, not asset size. A family with HK$240,000,000 — or several billion — of investments will almost never have EUR 750 million of consolidated revenue. The exposure belongs to the family whose group consolidates a substantial operating business: there, the 0% Schedule 16E rate drags down the Hong Kong effective rate and can trigger top-up tax, so the concession is collected back. Because the section 14 election is irrevocable, that configuration must be modelled before electing. The Hong Kong Pillar Two framework is analysed in The Global Minimum Tax and HKMTT in Hong Kong 2026.

The Tax Certainty Enhancement Scheme: the option for families below the threshold

The capital gains certainty scheme sits in Schedule 17K to Cap. 112, inserted by the Inland Revenue (Amendment) (Disposal Gain by Holder of Qualifying Equity Interests) Ordinance 2023 — Ord. No. 33 of 2023, gazetted 15 December 2023 — and carried into the Ordinance by section 40AX, which forms Part 6F. A gain on the disposal of equity interests is regarded as arising from the sale of a capital asset and is not chargeable to profits tax where the investor held at least 15% of the investee entity’s equity throughout the continuous period of 24 months immediately before the date of disposal.

The commencement test has two limbs, and the second is routinely dropped. Schedule 17K applies to a gain where (a) the disposal occurs on or after 1 January 2024 and (b) the gain accrues in the basis period for a year of assessment beginning on or after 1 April 2023. The scheme’s practical operation is confirmed by IRD Advance Ruling Case No. 77 of 28 November 2025, which applies “section 40AX of and Schedule 17K to the Inland Revenue Ordinance” expressly.

For a family below the HK$240,000,000 threshold this is the single most useful provision available, and it is routinely overlooked because it is not marketed as a family office measure. It requires no minimum assets, no Hong Kong employees, no HK$2,000,000 of spend, no irrevocable election and no licensed manager. The election is made in writing in the profits tax return. Insurers are excluded, as are non-listed interests in property traders, property developers, and entities whose immovable property exceeds half of total assets.

Other intersections in brief

Rule	How it relates to the FIHV regime
Territorial source	Foreign-sourced profits are outside the charge anyway; the concession is only valuable for Hong Kong-sourced profits
No capital gains tax	Genuine capital gains are untaxed regardless; the concession adds nothing
Dividends	Dividends from corporations that have borne Hong Kong tax are excluded from assessable profits without any concession
Stamp duty	No relief; contributing Hong Kong stock costs up to 0.2% plus HK$5
Transfer pricing, Part 8AA	Applies to the fee between the FIHV and the ESF Office
Double taxation agreements	A vehicle taxed at 0% may face difficulty obtaining a certificate of resident status; the IRD’s criteria are set out in Hong Kong Certificate of Resident Status and CDTA 2026
FHTP standard and the EU list	Schedule 16E’s substance require­ments exist because of international pressure; the direction of travel is one-way

The 2026 Bill: What Is Proposed and Why It Is Not Yet Law

The Bill was gazetted on 12 June 2026 and read a first time on 24 June 2026. As at 21 August 2026 it has not been passed. The measures are intended to apply retrospectively, from the year of assessment 2025/26.

Its full title is the Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026. It follows an FSTB industry consultation whose completion the Government confirmed on 2 April 2025, and an announcement in the 2026-27 Budget Speech.

The status is confirmed at primary level. The Government’s release of 12 August 2026 states that the Bill “is currently under scrutiny by the LegCo’s Bills Committee, with the clause-by-clause examination completed”, and that the Government “targets to resume second reading debate on the Bill within the second half of this year”. It further confirms: “Subject to passage by the LegCo, the relevant measures will take effect from the year of assessment 2025/26.”

The five groups of amendments, in the Government’s own words from the release of 12 June 2026: “(i) expanding the definition of ‘fund’; (ii) expanding the scope of qualifying investments; (iii) removing the 5 per cent threshold requirement for incidental transactions; (iv) relaxing the tax exemption treatment for special purpose entities (SPEs) and family-owned SPEs; and (v) introducing a series of enhancement measures to the tax regime for carried interest”. The same release adds that the unified funds exemption will acquire a tax reporting mechanism and economic substance requirements similar to those in the FIHV regime.

The stated policy aim, verbatim: “further attract private credit investment activities in the region, while complementing Hong Kong’s development in areas such as digital assets and trading of precious metals and commodities”.

The 2026-27 Budget Speech, delivered 25 February 2026, paragraph 98, verbatim: “The number of single-family offices in Hong Kong exceeds 3 300. To attract more family offices and funds to set up in Hong Kong, we will enhance our tax regime, including expanding the scope of ‘fund’ to cover specific funds-of-one, as well as classifying digital assets, precious metals, specified commodities, etc. as qualifying investments eligible for tax concessions.”

Item	Proposed change	Level of confirmation
5% incidental transactions rule	Abolished entirely	Primary — Government press release
Definition of “fund” in section 20AM	Expanded, including to funds-of-one	Primary — press release and Budget Speech
Schedule 16C asset classes	Expanded: digital assets, precious metals, specified commodi­ties	Primary — Budget Speech, paragraph 98
Schedule 16C, further classes	Loans and private credit; interests in non-corporate private entities; immovable property outside Hong Kong; insurance-linked securities; emission allowances, emission deriva­tives and carbon credits	Secondary — large international firm alerts
SPE and FSPE treatment	Relaxed: wider permissible activities; full concession for partially owned FSPEs	Primary as to “relaxing”, secondary as to detail
Carried interest, Schedule 16D	Hurdle rate require­ment abolished; HKMA certification abolished; extension to all Schedule 16C classes	Secondary
Unified funds exemption	Reporting mechanism and FIHV-style substance require­ment introduced	Primary as to the fact, secondaryas to figures
The HK$240,000,000threshold	No change announced in any primary source	—
The 95% tests and the 50-FIHVcap	No change announced in any primary source	—
Measurement basis of the threshold	Reported as moving from NAV to value of qualifying invest­ments, with loans from holders of direct beneficial interests no longer deducted	Secondary

Author’s assessment: the most consequential change for family offices is not in Schedule 16E but in Schedule 16C. The load-bearing parameters of the FIHV regime stay where they are. What expands is the list of assets whose transactions attract the zero rate — and that same list is the base on which the HK$240,000,000 threshold is measured. A family with a meaningful allocation to digital assets, precious metals or private credit cannot count those positions towards the threshold today; once the Bill passes, it can. That could carry structures over a threshold they currently fail.

A necessary caveat on confirmation. The Bill text on the Legislative Council portal remained closed to automated retrieval, and the Government Gazette portal requires acceptance of its terms of use before its indexes can be read. Every item marked secondary above therefore rests on alerts from large international law and accounting firms and has not been checked against the Bill text. Reporting on precious metals caps in particular is inconsistent: some firms report a 20% portfolio cap, one adds a separate 15% cap tied to commodity settlement, and one states expressly that no caps are specified. None of those figures is presented as fact in this analysis.

The Inland Revenue Department has introduced a transitional administrative measure with immediate practical effect. On 12 June 2026 the Department announced that eligible taxpayers may file their 2025/26 returns on the basis of the exemptions and concessions proposed in the Bill, pending approval by the Legislative Council. Author’s assessment: this is a helpful and unusual step, but it does not remove the risk — if the Bill is amended in committee, a return filed on the proposed basis will not match the enacted text. Clause-by-clause examination is complete, which makes committee stage amendments likely, and reconciliation against the final text will be necessary.

What the Bill does not contain. No statement in the Government’s releases, the Budget Speech or the firm alerts indicates any change to the HK$240,000,000 threshold, the 95% tests, the cap of fifty vehicles, the definition of family, the definition of ESF Office, or the two-employee and HK$2,000,000 requirements. The qualification matters: absence from commentary is weaker evidence than a reading of the Bill text, which was not available.

Hong Kong Against Singapore: Where a Family Office Costs More

Hong Kong and Singapore solve the same problem by opposite means. Hong Kong sets a high asset threshold and light operating obligations; Singapore sets a low asset threshold, heavy operating obligations, and prior regulatory approval.

There are three Singapore schemes, not two, and the third is recent. The Monetary Authority of Singapore’s own page refers to “the tax schemes for funds under sections 13O, 13OA and 13U of the Income Tax Act 1947”. Section 13OA exists because Singapore’s Budget 2024 extended the 13O scheme to limited partnerships registered in Singapore with effect from 1 January 2025. The IRAS overview of tax changes puts it plainly: “The section 13O scheme will be enhanced to include Limited Partnerships registered in Singapore.” Any statement that a 13O fund must be a company has been wrong since 1 January 2025.

Feature	Hong Kong FIHV (Schedule 16E)	Singapore 13O / 13OA	Singapore 13U
Minimum assets	HK$240,000,000(roughly S$40m) under the office’s manage­ment	S$20,000,000 in designated invest­ments	S$50,000,000in designated invest­ments
When tested	End of the basis period, with a look-back to either of two preceding years	Throughout the incentive period	Same
Regulatory approval	Not required; the election is made in the tax return	MAS approval required	MAS approval required
Investment profes­sionals	2 qualified full-time employees, “adequate in the opinion of the Commissioner”	2, at least 1 not a family member	3, at least 1 not a family member
Conditions on the profes­sionals	Full-time in Hong Kong, appropriately qualified	Portfolio manager, research analyst or trader; more than S$3,500 a month; more than 50% of time on the qualifying activity; Singapore tax resident throughout	Same
Minimum spending	HK$2,000,000 in Hong Kong	Tiered: AUM under S$50m — S$200,000; S$50m to under S$100m — S$500,000; S$100m and above — S$1,000,000, with a minimum of S$200,000 of local business spending in every band	Same
Capital deployment require­ment	None	Lower of S$10m or 10% of AUM in prescribed cate­gories, with multi­pliers	Same
Form and juris­diction of the vehicle	Any entity, in or outside Hong Kong	13O — a company incor­porated and resident in Singapore; 13OA — a limited part­nership regis­tered in Singapore	No form or juris­diction restriction
Definition of family	No generational limit	Under the MAS framework in force from 15 June 2026, no more than five genera­tions from a common ancestor	Same
Rate	0%	Exemption	Exemption
Mandatory bank account	Not required	Not stated as a condition on the scheme page	Not stated as a condition on the scheme page

Three of these differences carry real weight; the rest are secondary.

First, when the threshold is tested. Hong Kong measures assets at the end of the basis period, with a fallback to either of the two preceding years. The MAS scheme page requires the criteria to be met “throughout the incentive period”. A market drawdown is a Hong Kong non-event and a Singapore problem.

Second, prior approval. The Hong Kong regime is self-assessed: the FIHV files form S20 with its return, and eligibility is tested on audit. The Singapore schemes require MAS approval before the incentive applies. MAS publishes no indicative processing time; any figure circulating in the market is not a statement by the regulator.

Third, the independent professional. Singapore requires at least one investment professional who is not a family member. Section 10 of Schedule 16E contains no equivalent: both qualified full-time employees may be family members. For a family unwilling to admit an outsider to investment decisions, that alone can decide the jurisdiction.

The capital deployment requirement is the one substantial obligation with no Hong Kong analogue. A Singapore fund must deploy the lower of S$10,000,000 or 10% of AUM into MAS-prescribed categories, with the following multipliers:

Multiplier	Categories, per the MAS table
2x	Deeply conces­sional capital in blen­ded finance struc­tures with substantial involvement of financial institu­tions in Singapore; equities listed on MAS-approved exchanges; ETFs with primary mandates to invest in Singapore-listed equities on MAS-approved exchanges; non-listed funds distri­buted by licensed financial institu­tions in Singapore with the same primary mandate
1.5x	Only conces­sional capital in blen­ded finance struc­tures with substantial involvement of financial institu­tions in Singapore
1x	REITs, business trusts and ETFs whose primary mandate is not Singapore-listed equities, listed on MAS-approved exchanges; qualifying debt securities; non-listed funds distri­buted by licensed institu­tions with no Singapore mandate; invest­ments into non-listed Singapore operating companies; climate-related invest­ments; non-conces­sional capital in blen­ded finance struc­tures

Entities in the business of trading or holding Singapore immovable property are excluded from the requirement.

An important dating caveat on the Singapore material. The conditions above are taken from the live MAS scheme page, which itself carries the note “Published Date: 05 August 2024”. Alerts from large international firms — secondary only, not confirmed against the primary text — report that MAS issued Circular FDD Cir 05/2026 on 31 July 2026, effective 1 August 2026, changing, for single family office funds, when the asset test is measured, how investment professionals must be hired, the spending bands for the 13U scheme, and the capital deployment multipliers. The circular itself is closed to automated retrieval and the MAS scheme page does not reflect those changes. The Singapore block should therefore be read as the position on MAS’s published criteria, and the conditions should be checked with the regulator directly before any decision.

Singapore has one advantage Hong Kong does not answer — though its conditions are usually understated. The Singapore Philanthropy Tax Incentive Scheme grants a 100% tax deduction for overseas donations, capped at 40% of the donor’s statutory income. But the donations must be made through qualifying local intermediaries, the donor must be a single family office managing a 13O or 13U fund, and the donor must incur S$200,000 of incremental local business spending. Hong Kong has no equivalent; charitable giving runs through the general section 88 machinery of the Ordinance.

On regulatory burden, the gap has widened in Hong Kong’s favour. The revised single family office framework, settled by the Monetary Authority of Singapore in its published response to consultation feedback, took effect on 15 June 2026 — that is the commencement date, not the date the regulator settled the policy. It replaces the previous informal position with a class licensing exemption: the office must be incorporated in Singapore, file a Notice of Commencement within 14 days, file annual returns within four months of financial year end, and designate an employee ordinarily resident in Singapore; existing offices must file a Notice of Continuation by 15 June 2027. The primary instrument and the MAS media release both remained closed to automated retrieval; the elements listed here are corroborated by alerts from large international firms. For comparison: a Hong Kong family office serving only its own family requires no SFC licence and files nothing with a regulator at all.

> Author’s assessment: the comparison turns on asset size and on tolerance for outside participation. Below HK$240,000,000 the Hong Kong regime is simply unavailable, and Singapore at S$20,000,000 is the only route to a “regime” structure. Above it, Hong Kong is materially cheaper to run: no regulatory approval, no capital deployment requirement, no mandatory independent professional, no regulatory filings and no generational limit. The difference in thresholds is not a difference in quality — it is a difference in the segment each regime was built for.

FIHV, the Unified Funds Exemption, or an Ordinary Company?

For a Hong Kong family the unified funds exemption is almost always worthless, and an ordinary Hong Kong company is frequently no worse than an FIHV. The choice turns on three technical obstacles, not on the headline rate.

Feature	FIHV (Schedule 16E)	Unified funds exemption (ss. 20AM–20AY, Sch. 16C)	Ordinary Hong Kong private company
Rate on qualifying income	0%	Exempt under section 20AN	8.25% / 16.5%
Minimum assets	HK$240,000,000	None	None
Substance require­ment	2 employees + HK$2,000,000	None today; the 2026 Bill proposes an equivalent	None
Manager	The family’s ESF Office	A Type 9 licensed person, or qualified investment fund status	None required
Anti-round-tripping	Individuals fall outside the definition of resident person — section 20(2)	Sections 20AX and 20AY: a resident holding 30% or more is taxed on the profits	Not applicable
Election	Written and irrevocable	Not required	Not applicable
Loss ring-fencing	Yes, section 15	Yes	No
Cap on vehicles	50 per office	None	None

Obstacle one — anti-round-tripping under the fund exemption. Sections 20AX and 20AY deem a fund’s exempt profits to be those of a Hong Kong resident holding 30% or more of the beneficial interest. A family owns its vehicle outright. For a Hong Kong-resident family this cancels the section 20AN exemption entirely — and it is precisely why Schedule 16E needed a different definition of “resident person”.

Obstacle two — a family vehicle struggles to be a “fund”. Section 20AM of the Ordinance requires property to be managed as a whole or contributions to be pooled, and requires participating persons not to have day-to-day control. A single-family vehicle in which the founder directs investments has difficulty on both limbs.

Obstacle three — the alternative route fails on arithmetic. Qualified investment fund status requires more than four investors after final closing, over 90% of capital commitments from investors, and no more than 30% of net proceeds to the originator and its associates. A single family cannot satisfy this in any configuration. The only remaining path is to appoint an SFC Type 9 licensed corporation or a registered financial institution as the specified person carrying out or arranging the transactions in Hong Kong — an external manager, with the cost and loss of control that implies. The Hong Kong fund vehicles themselves — the OFC and the LPF — are analysed in Hong Kong Fund Structures in 2026: the OFC and the LPF.

Where a family with HK$100,000,000 ends up.

Not in an FIHV. HK$100,000,000 is well below the threshold, the two-year look-back cannot assist a family that was never above it, and aggregating across vehicles does not create assets that do not exist.

Not, realistically, in the unified funds exemption either. It has no minimum size, so on paper it is open. But a single-family vehicle almost certainly fails the section 20AM definition, qualified investment fund status is unreachable, and if the family is Hong Kong resident sections 20AX and 20AY hand the profits straight back. The 2026 Bill proposes to add an FIHV-style substance requirement to the fund regime, which would remove its last remaining advantage.

The answer is an ordinary Hong Kong private company or direct personal holding, and remarkably little is lost. Foreign-sourced profits are outside the charge on territorial principles. Capital gains are not taxed at all. Dividends from corporations that have borne Hong Kong tax are excluded from assessable profits. FSIE does not apply, because a purely Hong Kong family structure is not an MNE entity. Pillar Two is unreachable on the revenue threshold. And for Hong Kong equity interests the Schedule 17K certainty scheme delivers the result — 15% held for 24 months — with no assets test, no employees, no expenditure, no election and no external manager.

The arithmetic confirms it. On a HK$100,000,000 portfolio, even an atypically high 5% of Hong Kong-sourced revenue-nature profit is HK$5,000,000, taxed at roughly HK$660,000 under the two-tiered rates. The FIHV regime’s mandatory spend is HK$2,000,000 a year before professional fees and before stamp duty on funding. Even if the threshold were open, entering the regime would lose money.

Where the threshold bites hardest is the HK$150–240 million band. A family there already has real scale, already runs a family office, and already incurs expenditure comparable to the statutory requirement — and still gets nothing. Below that band the threshold is academic, because the running cost would be prohibitive regardless.

Context: How Many Family Offices Exist, and How Many Use the Regime

The official count records 3,384 single family offices in Hong Kong at the end of 2025. How many have used Schedule 16E is not published, and the Government describes the number of applications as “relatively small”.

The source of the headcount is the “Market Study on the Family Office Landscape in Hong Kong”, commissioned by InvestHK and released on 10 February 2026. The figures reported in Government releases. Note the last row carefully: the assets under management figure belongs to Hong Kong’s entire asset and wealth management sector, not to family offices, and should never be set beside the office count as though it were theirs.

Measure	Value	As at
Single family offices	3,384	end-2025
Two-year increase	+681, about 25%	from 2,703 at end-2023
Family offices’ annual contri­bution through operating expendi­ture	about HK$12.6 billion	2025
Full-time positions created	over 10,000	2025
Assets under manage­ment across Hong Kong’s whole asset and wealth manage­ment sector	about HK$35 trillion (about US$4.5 trillion)	end-2024

The 2026-27 Budget Speech uses the more conservative rounding “exceeds 3 300”. There is no conflict between “3,384”, “over 3,380” and “exceeds 3 300”: all three are true of the same number, and only the rounding differs. The most precise primary statement is the FSTB blog of 10 February 2026: “as of end-2025, the number of single family offices in Hong Kong has reached 3 384”. No later official count has been published: both the Secretary for Financial Services and the Treasury on 24 March 2026 and the Government’s reply to a legislative question on 22 April 2026 still cite the same end-2025 figure.

Take-up of the regime itself is not published, and that is a policy position rather than an omission. Answering a legislative question on 30 July 2025, the Government stated that for the years of assessment 2022/23 and 2023/24 it had received “a relatively small number of applications for tax concession for FIHVs”, and declined to give a breakdown because it “may not be appropriate… to avoid disclosing the information of the taxpayers”, adding that the regime “is still at its early stage” and that the current number of applications “may not be an appropriate indicator of the effectiveness of the tax concession regime”.

Author’s assessment: setting those two figures side by side — 3,384 offices and a “relatively small number” of applications — is the single most informative fact about this regime. Family offices are arriving; few are claiming the concession. The likely reasons are visible in the statute itself: the threshold is measured in Schedule 16C assets rather than total wealth; the election is irrevocable; there is no DIPN, so certainty requires an advance ruling; and many families already pay close to nothing in Hong Kong without any concession at all. Any numeric estimate of take-up encountered in commentary has no primary source behind it.

The surrounding policy programme is substantially delivered. The Policy Statement on Developing Family Office Businesses of 24 March 2023 contained eight measures. The only one not yet in operation as at August 2026 is the art and valuables storage and display facility at the airport: the operating contract for the 53,000 sq ft SKYTOPIA Art & Valuables Storage Facility was signed on 18 March 2026, with operations expected to commence in early 2027. The Government has published no official “seven of eight” score; that is an inference from the status of each measure. The Network of Family Office Service Providers launched on 12 June 2023, the Hong Kong Academy for Wealth Legacy under the Financial Services Development Council on 14 November 2023, and the Hong Kong Family Office Nexus digital knowledge hub on 27 March 2025.

The FIHV regime confers no immigration benefit. Schedule 16E is a profits tax regime and nothing more. Residence for capital owners runs through the separate New Capital Investment Entrant Scheme, launched 1 March 2024, with an investment requirement of HK$30,000,000 and a net asset requirement of HK$30,000,000, administered jointly by InvestHK and the Immigration Department.

The two regimes do cross-reference each other, but in one direction only. Since 1 March 2025 a New CIES applicant may make permissible investments through a wholly owned Hong Kong private company, provided that company is an FIHV or an FSPE under an FIHV managed by an eligible single family office as defined in section 2 of Schedule 16E. The Scheme Rules are more precise and cite three different provisions: an FIHV is defined in section 5, an FSPE in section 6, and an eligible single family office in section 2 of Schedule 16E. From 1 March 2026 an applicant may use an eligible private holding company set up less than six months before the application, “without a minimum incorporation period”. Schedule 16E’s definitions are borrowed as an eligibility gate for an optional structuring route — but no election for the 0% rate is required for New CIES purposes, and electing confers no immigration advantage. Hong Kong’s immigration routes are covered in Hong Kong Work and Relocation Visas 2026.

Step-by-Step: Building a Structure for the FIHV Regime

Sequence matters. Stamp duty, the 95% test and the irrevocability of the election are all tied to moments that cannot be replayed afterwards.

1.        Count Schedule 16C assets, not total wealth. Real estate, physical metals, art and operating stakes outside the eleven classes are excluded. A figure below HK$240,000,000 ends the analysis here.

2.        Establish whether there is any Hong Kong tax to save. Foreign-sourced profits, capital gains and dividends from Hong Kong-taxed corporations are untaxed without any concession. With no Hong Kong-sourced taxable base, the regime has no economic point.

3.        Model the global minimum tax. If the family’s group consolidates an operating business with EUR 750 million of revenue, the 0% rate can trigger top-up tax. Test this before electing — the election is irrevocable.

4.        Map the family under section 4 of Schedule 16E. Fix Person A and chart the related persons, including siblings of the lineal ancestors of both spouses and all their descendants.

5.        Compute the family holding under Schedules 16F, 16G and 16H. A look-through calculation through every interposed entity, trust and foundation. The target is 95%, or 75% where a charitable entity participates and unrelated persons hold no more than 5%.

6.        Keep every interposed entity passive. Any entity between the family and the FIHV that carries on a trade or business falls outside the section 22(8) carve-out and risks attribution.

7.        Incorporate the family office as a Hong Kong private company. Management and control in Hong Kong. Schedule 16E permits no other form for the office.

8.        Set the office’s fee at market level. Too low weakens the safe harbour; too high increases tax at 16.5%. Prepare transfer pricing documentation.

9.        Keep material assets off the office’s balance sheet. Income from them inflates the denominator of the FOMP formula and erodes the safe harbour percentage.

10.    Choose the FIHV’s form and jurisdiction. Any entity, in or outside Hong Kong — but management and control must sit in Hong Kong.

11.    Price stamp duty before funding. Hong Kong stock costs up to 0.2% plus HK$5, with no section 45 relief for individuals or trustees. Contribute offshore holding companies rather than Hong Kong shares where possible.

12.    Hire the qualified employees early. The test is on the average number over the basis period; a year-end hire produces no average.

13.    Budget Hong Kong expenditure above the floor. Ruling No. 73 shows HK$3,000,000 and then HK$10,000,000 against multi-billion assets; the HK$2,000,000 minimum is a floor, not a benchmark.

14.    Make the section 14 election on form S20 with the return. The form is filed electronically only, through the Business Tax Portal or Tax Representative Portal. The election is irrevocable.

15.    Consider an advance ruling. There is no DIPN, so a ruling is the only route to certainty on a specific structure. Ruling No. 73 runs from 2023/24 onwards for the regime and from 2023/24 to 2027/28 on the FSIE points.

16.    Set up beneficial ownership record-keeping. Records are maintained throughout the holding period and retained for seven years after cessation, by both the FIHV and the ESF Office.

17.    Track the 2026 Bill. Clause-by-clause examination is complete, the second reading is targeted for the second half of 2026, and the measures are to apply from the year of assessment 2025/26. The IRD’s transitional measure already permits a 2025/26 return on the proposed basis.

Common Mistakes and What They Cost

Mistake 1. Measuring the threshold against total family wealth. Real estate, physical metals, art, aircraft and operating stakes outside the eleven classes do not count. Cost: discovery on audit, denial of the concession for every year claimed, and assessment at 8.25% and 16.5% with interest.

Mistake 2. Assuming two employees and HK$2,000,000 are sufficient by definition. Section 10(1) requires both to be “adequate in the opinion of the Commissioner”. Cost: a dispute where the asset base is disproportionate to the staffing, and loss of the concession for the entire year — not merely for one transaction.

Mistake 3. Electing under section 14 without modelling Pillar Two. For a family with a large operating business in the group, the 0% rate depresses the Hong Kong effective rate and can trigger top-up tax. Cost: permanent, because the election is irrevocable — the tax is collected back while loss ring-fencing under section 15 remains.

Mistake 4. Contributing Hong Kong shares directly from an individual. Section 45 relief is available only between associated bodies corporate. Cost: up to 0.2%, or up to HK$480,000 on a HK$240,000,000 portfolio, paid on the way in before any benefit accrues.

Mistake 5. Holding the office’s own investments on its balance sheet. That income enters the FOMP denominator without entering the numerator. Cost: failure of the section 3 safe harbour, loss of ESF Office status, and the collapse of the regime across every FIHV that office manages — up to fifty at once.

Mistake 6. Interposing an operating holding company between the family and the FIHV. The section 22(8) carve-out requires a specified entity not to carry on any trade or business. Cost: attribution of the FIHV’s assessable profits to that company under section 22 — the benefit lost entirely while every cost of the regime remains.

Mistake 7. Granting hired managers more than 5% of the family office. The unrelated-person ceiling inside the relief is exactly 5%. Cost: loss of ESF Office status and of the regime across all connected vehicles; the incentive plan costs far more than it is worth.

Mistake 8. Treating the 95% test as a year-end snapshot. “At all times during the basis period” makes it continuous. Cost: a brief dilution during an intra-family transfer or a succession event fails the whole year on the face of the statute.

Mistake 9. Trading private company stakes on a short horizon. Sections 12 and 13 require two years of holding, or absence of control, or short-term assets not exceeding 50% where control exists. Cost: profits on that transaction taxed at ordinary rates while loss ring-fencing under section 15 still applies.

Mistake 10. Holding Hong Kong immovable property inside the FIHV. It is outside Schedule 16C, and a substantial letting operation puts section 5(1)(b) in question. Cost: ordinary rates on the property income plus the risk of losing FIHV status altogether.

Mistake 11. Splitting management of one FIHV between two family offices. Section 14(1)(b) requires management by only one ESF Office. Cost: section 9 does not apply to that vehicle at all, however perfectly every other condition is met.

Mistake 12. Overlooking that incidental transactions are measured on receipts. The section 9(5) base is trading receipts, not profits. Cost: a low-margin, high-turnover activity breaches 5% and pushes the associated profits out of the zero rate.

Mistake 13. Relying on the IRD’s transitional measure without reconciling to the enacted text. The measure of 12 June 2026 permits a 2025/26 return on the proposed basis, but the Bill is unenacted and committee amendments are likely. Cost: amended returns and additional assessments if the final text departs from the filed position.

Mistake 14. Not seeking an advance ruling for a non-standard structure. There is no DIPN; the Department’s position is known only from its webpage and from the single published ruling. Cost: uncertainty surfaces years later, on audit, when the irrevocable election makes restructuring impossible.

Who the Regime Suits, Who It Does Not, and When to Take Advice

It suits:

•          families holding HK$240,000,000 or more of Schedule 16C assets whose profits are materially Hong Kong-sourced and revenue in nature — that is, active trading managed from Hong Kong;

•          families already running, or willing to run, a Hong Kong family office whose staffing and expenditure comfortably exceed the statutory floor;

•          multi-generational families with wide collateral branches, since the Hong Kong definition of family carries no generational limit;

•          families intent on keeping investment decisions in-house: Hong Kong imposes no independent investment professional requirement;

•          structures needing several separate vehicles — by branch, generation or asset class — up to fifty per office, with the threshold tested once in aggregate;

•          families whose structure sits outside any group with EUR 750 million of consolidated revenue.

It does not suit:

•          families below HK$240,000,000 of Schedule 16C assets; there is no route around the threshold, and the look-back helps only those who once cleared it;

•          families whose profits are already untaxed: foreign-sourced income, capital gains, dividends from Hong Kong-taxed corporations;

•          families whose group consolidates a large operating business, where the zero rate works against the structure under Pillar Two and the election cannot be reversed;

•          structures in which outsiders hold more than 5% of the office or the vehicle;

•          families intending to hold Hong Kong immovable property or to trade private company stakes on a horizon shorter than two years;

•          anyone expecting an immigration benefit: Schedule 16E confers none.

Professional review is essential:

•          before the section 14 election — it is irrevocable, and every consequence, including loss ring-fencing and the Pillar Two interaction, is permanent;

•          before funding the structure — stamp duty depends on the order of steps and the character of the asset contributed;

•          wherever there is an interposed entity between the family and the FIHV — the section 22(8) carve-out requires it to carry on no trade or business;

•          wherever a charitable entity participates — the “Condition 1 plus Condition 2” relief has its own anti-circumvention rules in sections 2(6) and 2(7);

•          wherever there are transactions in private company securities — the sections 12 and 13 tests were taken as assumptions in Ruling No. 73, not adjudicated;

•          for any non-standard structure — the absence of a DIPN makes an advance ruling the only route to certainty.

Frequently Asked Questions

How much money do you need to open a family office in Hong Kong with the tax concession? At least HK$240,000,000 of aggregate net asset value in Schedule 16C assets under the family office’s management. The threshold is tested at the end of the basis period; if it is not met, the end of the basis period for either of the two preceding years may be used instead — but only where the office already existed in that year.

Does the FIHV have to be a Hong Kong entity? No. Section 5(1) of Schedule 16E expressly contemplates an entity established “in or outside Hong Kong”. The Hong Kong requirement lies elsewhere: section 9(4)(a) requires the FIHV to be “normally managed or controlled in Hong Kong”. The family office, unlike the FIHV, must be a Hong Kong private company.

Does the family office pay tax in Hong Kong? Yes, and this is a condition of the regime. Section 2(2)(c)(ii) requires the office’s service fees to be chargeable to profits tax under section 14 of the Ordinance, at the ordinary rates of 8.25% on the first HK$2,000,000 of assessable profits and 16.5% above.

Does a Hong Kong family office need an SFC licence? A family office serving only its own family and not managing third-party assets is not licensable under the Securities and Futures Ordinance. This distinguishes Hong Kong from Singapore, where since 15 June 2026 a class licensing exemption framework applies with mandatory notifications and annual returns to MAS.

Can the election into the FIHV regime be withdrawn? No. Section 14(4) of Schedule 16E: “An election under this section, once made, is not revocable by the FIHV concerned.” The IRD confirms that the election is made in writing, applies to all subsequent years without annual repetition, and is irrevocable.

How many vehicles can one family run under the regime? No more than fifty FIHVs may elect through a single ESF Office — section 14(3). Each FIHV must be managed by only one office. The HK$240,000,000 threshold is tested across all the vehicles of one office in aggregate.

Does real estate count towards the concession? No. The eleven Schedule 16C classes contain no immovable property. Profits from directly held Hong Kong property are taxed at the ordinary rates, and a substantial letting operation may put compliance with section 5(1)(b) in question. The 2026 Bill proposes to add immovable property outside Hong Kong, preserving the exclusion for Hong Kong property.

What happens if the family’s holding falls below 95%? The tests in sections 2(2)(a) and 5(1)(a) are framed “at all times during the basis period” and are therefore continuous. Where a charitable entity is among the holders, the test is treated as satisfied on a family holding of 75% to 95%, provided unrelated persons hold no more than 5% in aggregate. Outside that relief, any dip below 95% during the period fails the year on the face of the statute.

Does the FIHV regime give a right to live in Hong Kong? No. Schedule 16E is a profits tax regime only. Residence runs through the separate New Capital Investment Entrant Scheme, with an investment requirement of HK$30,000,000. The link between the two is one-way: since 1 March 2025 a New CIES applicant may invest through a company that is an FIHV or an FSPE, but no election for the 0% rate is required to do so.

How does the Hong Kong regime differ from Singapore’s 13O? The asset threshold is higher in Hong Kong — HK$240,000,000 against S$20,000,000. Against that, Hong Kong requires no regulatory approval, no capital deployment and no independent investment professional, imposes no generational limit on the definition of family, and does not require the vehicle to be incorporated in the jurisdiction. Note also that there are three Singapore schemes, not two: since 1 January 2025 the 13O scheme has extended to limited partnerships registered in Singapore through section 13OA, so the statement that a 13O fund must be a company is out of date.

Has the Inland Revenue Department issued guidance on the regime? No DIPN on the FIHV regime has been issued. The Departmental Interpretation and Practice Notes run to No. 63 (November 2023) and none addresses Schedule 16E. During the passage of the 2022 Bill the Administration told the Bills Committee that a DIPN would follow enactment; it has not. The practical guides are the IRD’s webpage on the regime, which refers readers to DIPN 31 “Advance Rulings”, and the published Advance Ruling Case No. 73 of 17 January 2024. The published ruling series now runs to No. 78, but only No. 73 addresses Schedule 16E.

Has the 2026 Bill been passed? No. As at 12 August 2026 it remains before the Legislative Council’s Bills Committee with clause-by-clause examination complete, and resumption of the second reading debate is targeted for the second half of 2026. The measures are intended to apply from the year of assessment 2025/26. Since 12 June 2026 an IRD transitional administrative measure permits eligible taxpayers to file 2025/26 returns on the proposed basis.

Can the Government change the threshold or the rate without legislation? Yes. Section 40AW(1) of Cap. 112 empowers the Secretary for Financial Services and the Treasury, by notice in the Gazette, to amend the employee number in section 10(1)(b)(ii), the amounts in sections 10(1)(c)(ii) and 11(2), (4) and (6), and the rates in sections 24(2) and 25(2) of Schedule 16E.

Key Takeaways

•          The legal basis is Schedule 16E to Cap. 112, inserted by Ord. No. 8 of 2023 (passed 10 May, in operation 19 May 2023), applying from the year of assessment commencing 1 April 2022. The version in force has a point in time of 6 June 2025.

•          The Schedule runs to six Parts and 29 sections and depends on sections 40AV and 40AW of Cap. 112 and on six supporting Schedules, 16F to 16K.

•          The 0% rate is in section 24(2) for FIHVs and section 25(2) for FSPEs — not in section 9.

•          The threshold is HK$240,000,000 of aggregate NAV in Schedule 16C assets under the office’s management, with a fallback to either of the two preceding years where the office existed then.

•          Substance is at least 2 qualified employees and at least HK$2,000,000 of expenditure, both of which must additionally be “adequate in the opinion of the Commissioner”: the minimum does not guarantee compliance.

•          There are two 95% tests — the office under section 2(2)(a) and the FIHV under section 5(1)(a) — each relieved to 75% where a charitable entity participates and unrelated persons hold no more than 5%.

•          The family office pays ordinary profits tax; its fees must be chargeable under section 14 of the Ordinance.

•          The safe harbour is 75% of management profits from the family’s own specified persons, computed as FOMP ÷ P, where the denominator captures all the office’s profits from every source.

•          The election is mandatory and irrevocable, made on form S20 and filed electronically; no more than 50 FIHVs per office; each FIHV managed by only one office.

•          Anti-round-tripping misses family members because section 20(2) confines “resident person” to corporations, partnerships and trustees; for entities it operates at 30%, and the section 22(8) carve-out requires an interposed entity to carry on no trade or business.

•          Losses are ring-fenced — sections 15 and 19.

•          There is no stamp duty relief: contributing Hong Kong stock costs up to 0.2% plus HK$5, and section 45 of the Stamp Duty Ordinance is unavailable to individuals and trustees.

•          No DIPN exists; the only guides are the IRD’s webpage and Advance Ruling Case No. 73 of 17 January 2024.

•          The 2026 Bill is unenacted; the measures are intended from the year of assessment 2025/26, with an IRD transitional filing measure in place since 12 June 2026.

•          The threshold, the employee number, the expenditure figure and the rate itself can all be changed by notice in the Gazette under section 40AW — without a Bill.

Summary 

The Hong Kong family office tax concession is granted under Schedule 16E to the Inland Revenue Ordinance (Cap. 112), inserted by Ord. No. 8 of 2023 (passed 10 May 2023, in operation 19 May 2023) and applying from the year of assessment commencing 1 April 2022; the version in force has a point in time of 6 June 2025 following consequential cross-reference amendments made by section 32 of Ord. No. 21 of 2025. The Schedule runs to six Parts and 29 sections, is carried into the Ordinance by sections 40AV and 40AW, and depends on six supporting Schedules, 16F to 16K. The profits tax rate is 0% for a family-owned investment holding vehicle under section 24(2) and for a family-owned special purpose entity under section 25(2), on profits from transactions in the eleven classes of Schedule 16C assets and on incidental transactions within 5% of trading receipts. The conditions are: aggregate net asset value of Schedule 16C assets under the family office’s management of at least HK$240,000,000 at the end of the basis period or either of the two preceding years (section 11); at least two qualified full-time employees in Hong Kong and at least HK$2,000,000 of Hong Kong operating expenditure, both additionally required to be adequate in the Commissioner’s opinion (section 10); at least 95% of the beneficial interest held by family members in both the family office (section 2(2)(a)) and the FIHV itself (section 5(1)(a)), relieved to 75% where a charitable entity participates and unrelated persons hold no more than 5%; at least 75% of the office’s management profits from serving its own family under the FOMP formula (section 3); and the office’s fees chargeable to profits tax under section 14 at 8.25% and 16.5%. A written irrevocable election under section 14 is required, made on supplementary form S20; no more than 50 FIHVs may elect through one office and each must be managed by only one office. Losses are ring-fenced (sections 15 and 19); transactions in private company securities are subject to the tests in sections 12 and 13 (10% immovable property, two-year holding period, 50% short-term assets); and the anti-round-tripping rule in section 22 does not reach natural persons because section 20(2) defines a resident person only as a corporation, a partnership or a trustee. No DIPN has been issued; the only published ruling is Advance Ruling Case No. 73 of 17 January 2024. Hong Kong recorded 3,384 single family offices at the end of 2025, while the Government describes applications for the concession in 2022/23 and 2023/24 as “a relatively small number”. The Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026, gazetted 12 June 2026 and read a first time on 24 June 2026, remained unenacted as at 21 August 2026; its measures are intended to apply from the year of assessment 2025/26, and since 12 June 2026 an Inland Revenue Department transitional measure has permitted 2025/26 returns to be filed on the proposed basis.

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Sources

Primary Hong Kong legislation (consolidated texts, Hong Kong e-Legislation)

1.        Inland Revenue Ordinance (Cap. 112) — consolidated text

2.        Schedule 16E to Cap. 112, “Tax Treatment of Family-owned Investment Holding Vehicle and Family-owned Special Purpose Entity”, version in force at 6 June 2025

3.        Sections 40AV and 40AW of Cap. 112 (Part 6E) — carrying Schedule 16E into the Ordinance and the power to amend it

4.        Schedule 16C to Cap. 112, “Classes of Assets Specified for Transactions for Purposes of Sections 20AN and 20AO and Schedule 16E”

5.        Schedule 16D to Cap. 112, “Eligible Carried Interest and its Tax Treatment”

6.        Schedule 16F to Cap. 112 — extent of a family member’s beneficial interest

7.        Schedule 16G to Cap. 112 — extent of an unrelated natural person’s beneficial interest

8.        Schedule 16H to Cap. 112 — extent of one entity’s beneficial interest in another

9.        Schedule 16I to Cap. 112 — extent of an FIHV’s beneficial interest in an FSPE

10.    Schedule 16J to Cap. 112 — computing a resident person’s assessable profits under section 22 of Schedule 16E

11.    Schedule 16K to Cap. 112 — computing a resident person’s assessable profits under section 23 of Schedule 16E

12.    Stamp Duty Ordinance (Cap. 117) — consolidated text

13.    Securities and Futures Ordinance (Cap. 571) — consolidated text

Enacting and amending Ordinances

14.    Government announcement of the passage of the Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance 2023 — Ord. No. 8 of 2023, 10 May 2023

15.    Policy Statement on Developing Family Office Businesses in Hong Kong, 24 March 2023

16.    Policy Statement, full text, PDF

17.    Announcement of the reduction of stamp duty on stock transfers to 0.1%, 15 November 2023

Inland Revenue Department (IRD)

18.    Tax Concessions for Family-owned Investment Holding Vehicles — the regime page

19.    Advance Ruling Case No. 73, issued 17 January 2024

20.    Index of published IRD advance rulings

21.    Advance Ruling Case No. 77, issued 28 November 2025 — applying section 40AX and Schedule 17K

22.    Departmental Interpretation and Practice Notes — full list

23.    DIPN 61, “Profits Tax Exemption for Funds” — dated June 2020 and never revised since; used here only for context on the unified funds exemption, with every Schedule 16C provision checked against the consolidated text of the Schedule

24.    DIPN 31, “Advance Rulings” — the procedure to which the IRD’s FIHV page refers

25.    Profits tax rates and the two-tiered regime

26.    Tax Certainty Enhancement Scheme for onshore equity disposal gains

27.    IRD FAQ on the Tax Certainty Enhancement Scheme — the 15% and 24-month conditions

28.    Inland Revenue (Amendment) (Disposal Gain by Holder of Qualifying Equity Interests) Ordinance 2023 — Ord. No. 33 of 2023, gazetted text

29.    Foreign-sourced Income Exemption regime

30.    FSIE — IRD illustrative examples

31.    Global Minimum Tax and Hong Kong Minimum Top-up Tax — IRD page

32.    Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 — Ord. No. 21 of 2025, gazetted text

33.    Stamp duty — general page, including section 45 relief

34.    Stamp duty rates, including transfers by way of voluntary disposition inter vivos — GovHK

35.    IRD stamp duty FAQ

36.    IRD list of amendments to the Stamp Duty Ordinance (Cap. 117)

37.    Form IRSD124 — statutory declaration for relief under section 45 of the Stamp Duty Ordinance

38.    Stamp Office circular on collection of duty where no adjudication has been sought

39.    2026-27 Budget tax measures — IRD page

40.    Completion of profits tax returns and supplementary forms — IRD FAQ

41.    Completion of profits tax returns and supplementary forms S1 to S22 — IRD page

42.    IRD forms index, including supplementary form S20 (BIRS20)

43.    IRD “What’s New” feed

44.    IRD press release on the gazettal of the 2026 Bill, 12 June 2026

45.    IRD press release on the status of the 2026 Bill, 12 August 2026

46.    IRD reply to the legislative question on the FIHV regime, 30 July 2025

47.    IRD press release on completion of the industry consultation, 2 April 2025

48.    Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Ordinance 2022, text hosted by IRD

49.    Bills Committee report on the FIHV Bill, paper CB(1)352, 21 April 2023

The 2026 Bill and Legislative Council papers

50.    Government announcement of the gazettal of the Inland Revenue (Amendment) (Preferential Tax Regimes for Funds, Family-owned Investment Holding Vehicles and Carried Interest) Bill 2026, 12 June 2026

51.    Government statement on the Bill’s status and the year of assessment 2025/26, 12 August 2026

52.    Bill text on the Legislative Council portal (automated access restricted)

53.    LegCo Brief on the Bill, ASST/3/1/5C(2026), 10 June 2026

54.    LegCo Panel on Financial Affairs paper on the proposed FIHV regime, 4 April 2022

55.    Bills Committee paper recording the undertaking to issue a DIPN

Budget and Policy Address

56.    2026-27 Budget Speech, 25 February 2026, PDF

57.    2026-27 Budget — revenue measures, including paragraph 103 on section 45 of the Stamp Duty Ordinance

58.    Government press release on the 2026-27 Budget Speech, 25 February 2026

59.    2025 Policy Address, 17 September 2025, full text

Family office policy and statistics

60.    Government announcement of the family office market study, 10 February 2026

61.    Speech by the Secretary for Financial Services and the Treasury at the Wealth for Good Summit, 24 March 2026

62.    Financial Services and the Treasury Bureau blog on the study’s findings, 10 February 2026

63.    Government announcement of the first family office market study, 18 March 2024

64.    Government reply to legislative question LCQ9 on the FIHV regime and family offices, 30 July 2025

65.    Government reply to legislative question LCQ18, 22 April 2026

66.    Launch of the Network of Family Office Service Providers, 12 June 2023

67.    Network of Family Office Service Providers — FamilyOfficeHK directory

68.    Establishment of the Hong Kong Academy for Wealth Legacy, 14 November 2023

69.    Hong Kong Academy for Wealth Legacy — FSDC page

70.    Launch of the Hong Kong Family Office Nexus digital knowledge hub, 27 March 2025

71.    Achievement of the family office target and the new 2026-2028 target, 15 September 2025

72.    Government statement on the philanthropy strand of the policy programme, 27 May 2026

73.    Airport Authority Hong Kong — signing of the operating contract for the SKYTOPIA Art & Valuables Storage Facility, 18 March 2026

New Capital Investment Entrant Scheme

74.    New Capital Investment Entrant Scheme — official site

75.    New CIES Scheme Rules, PDF

76.    New CIES new measures, including the changes effective 1 March 2026

77.    Announcement of the launch of New CIES and the structure of the threshold, 19 December 2023

78.    New CIES changes effective 1 March 2025, including the reference to section 2 of Schedule 16E, 7 January 2025

79.    Admission of residential property as a permissible investment, 16 October 2024

80.    Two-year milestone of New CIES, InvestHK

81.    Government announcement of the New CIES two-year milestone and the 1 March 2026 change, 2 March 2026

82.    Government reply to a legislative question on New CIES, including the six-month net asset test, 26 March 2025

Securities and Futures Commission of Hong Kong

83.    SFC FAQ on the licensing of family offices

International context and listings

84.    Removal of Hong Kong from the EU watchlist, 20 February 2024

85.    FSTB consultation paper on the global minimum tax and the HKMTT, PDF

Singapore — comparative material

86.    Fund Tax Incentive Scheme for Family Offices — Monetary Authority of Singapore

87.    MAS FAQ on the schemes for family offices

88.    Philanthropy Tax Incentive Scheme for Family Offices — MAS

89.    Income Tax (Amendment) Bill No. 32/2024 — introducing section 13OA, Parliament of Singapore

90.    Overview of tax changes, Singapore Budget 2024, IRAS

91.    Overview of tax changes, Singapore Budget 2023, IRAS — conditions of the Philanthropy Tax Incentive Scheme

92.    MAS media release on the revised framework for single family offices taking effect on 15 June 2026

93.    Annex C-2 to Singapore Budget 2025, Ministry of Finance

94.    Public consultation on the proposed Finance (Income Taxes) Bill 2026, Ministry of Finance Singapore

95.    Global Investor Programme factsheet, Singapore Economic Development Board, updated 5 May 2025

A note on secondary sources. Those elements of the 2026 Bill marked in the text as secondary-only are taken from alerts published in June and July 2026 by large international law and accounting firms (KPMG, Baker McKenzie, DLA Piper, Sidley Austin, Deacons, Withers, PwC). They have been used solely for cross-checking and are not listed above, because the primary Bill text remained closed to automated retrieval. Every statement of the law in force in this analysis has been verified against the consolidated text of Cap. 112 on Hong Kong e-Legislation.

Disclaimer

This material is provided for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before acting on any of it, obtain individual professional advice reflecting your specific circumstances, jurisdiction, corporate status and the regulators’ current requirements.

Position stated as at: August 2026.