ARH Consultancy

Business Relocation · Destination

Relocating a business to Hong Kong

Hong Kong taxes profits by source rather than by residence. That territorial principle is the whole attraction, and it is also the part that has to be documented rather than assumed.

Tax and corporate landscape

  • Profits tax operates on a two-tier basis, with a lower rate on the first tranche of assessable profits and a standard rate above it.
  • Tax applies only to profits sourced in Hong Kong; offshore profits can fall outside the charge where the source position holds.
  • No VAT or GST, and no tax on dividends or capital gains.
  • Offshore claims are examined closely and must be supported by where the profit generating activity actually happens.
  • A refined foreign sourced income exemption regime applies to certain passive income received by in-scope groups.
  • Salaries tax on individuals is low by international standards and also territorially limited.

Substance and residency

  • A company secretary and a registered Hong Kong office are required.
  • There is no local director requirement, but an offshore claim is far harder to defend without local decision making.
  • Employment visas for founders and staff run through the General Employment Policy route.
  • Annual audited accounts by a Hong Kong practising accountant are mandatory, even for small companies.
  • Significant controllers register and annual returns must be maintained.
  • Banking due diligence is thorough and expects a clear, verifiable business rationale.

Timeline and cost drivers

  1. 01

    Weeks 1 to 4

    Feasibility and source analysis, entity choice, UK exit modelling and founder residence planning before anything is filed.

  2. 02

    Weeks 2 to 8

    Incorporation, business registration certificate, company secretary appointment and bank account opening.

  3. 03

    Weeks 8 to 18

    Visa applications, office and payroll setup, migration of contracts and IP, and the evidence file supporting any offshore claim.

What ARH handles

  • Country assessment comparing Hong Kong with your other shortlisted destinations on commercial and tax grounds.
  • Source analysis testing whether an offshore claim is realistic for your actual operations.
  • UK exit position: corporate deemed disposal exposure, temporary non-residence and the founder's Statutory Residence Test path.
  • Structure design for where IP, contracts and profit should sit, and the audit trail behind it.
  • Implementation roadmap with costs, dependencies, risks and sequencing.
  • Coordination and quality control across every local adviser on the file.

What local partners handle

  • Incorporation and Companies Registry filings.
  • Company secretary and registered office services.
  • Employment visa applications.
  • Statutory audit and profits tax returns.
  • Bookkeeping, payroll and MPF registration.
  • Office space and commercial leases.

We coordinate these partners, we do not hold offices in this market. See our relocation approach and our guide to offshore company formation.

Sources

Rates, thresholds and regimes change. Treat this page as an orientation, not as advice for your position.

Private Consultation

A conversation, in confidence.

Every engagement begins with a structured discovery, an honest read of your position, your ambitions, and the jurisdictions where they align.

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