Hong Kong introduces corporate redomiciliation

On 20 December 2024, the Hong Kong Government published a Bill to amend the Companies Ordinance to introduce a mechanism for redomiciliation. The bill was tabled in the Legislative Council on 8 January 2025. It passed: the Companies (Amendment) (No. 2) Ordinance 2025 came into operation on 23 May 2025, the regime now sits in Part 17A of the Companies Ordinance, and the Companies Registry has been accepting applications since that day. Foreign companies can transfer their incorporation to Hong Kong while maintaining their legal personality and business continuity.

The main provisions of the redomiciliation regime are:

• Redomiciliation procedure:

Companies that meet the established requirements can redomicile to Hong Kong without having to liquidate or reincorporate. This preserves their legal identity and business continuity.

• Tax considerations:

A redomiciled company is treated as incorporated in Hong Kong for tax purposes. However, under Hong Kong's territorial tax system, it is not subject to income tax until it commences business operations in the region.

Under certain conditions, unilateral tax credits may be granted for taxes paid on unrealized profits in the jurisdiction of original incorporation or domicile.

Transitional tax mechanisms clarify the tax treatment of various assets and liabilities. However, these measures do not apply to companies that were already doing business in Hong Kong prior to redomiciliation.

How it is working in practice

As of August 2026 the regime has a full year of statistics behind it. By the end of June 2026 the Companies Registry had received 70 applications and completed 42 re-domiciliations, among them two insurers and one listed company. The companies that moved came from jurisdictions such as the British Virgin Islands, the Cayman Islands, Bermuda and Luxembourg — the classic offshore and holding jurisdictions.

"The redomiciliation mechanism is designed to ensure a level playing field for all market participants and simplify the process of relocating a business to Hong Kong. This helps to increase the attractiveness of Hong Kong for foreign companies interested in a stable and favorable business environment."

By contacting us, you will receive:

• Advice on redomiciliation of companies to Hong Kong, including an analysis of requirements and procedures.
• Consultations on tax planning and tax optimization in accordance with Hong Kong legislation.
• Assessment of the benefits and potential risks of moving a business to Hong Kong.
• Support for the redomiciliation process, including preparation of necessary documents and interaction with regulatory authorities.
• Support on corporate governance issues, including development of internal policies and procedures that comply with local requirements.