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Mainland China’s Individual Income Tax Reform: Implications for Expats – Tax.HK
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Mainland China’s Individual Income Tax Reform: Implications for Expats

📋 Key Facts at a Glance

  • Hong Kong’s Tax Advantage: Hong Kong does not tax capital gains, dividends, or inheritance, and operates on a territorial basis for profits tax.
  • Competitive Personal Tax: Salaries tax is capped at a standard rate of 15% on the first HK$5 million and 16% above that, with generous personal allowances.
  • Simplified Property Market: As of 28 February 2024, all Special, Buyer’s, and New Residential Stamp Duties have been abolished, simplifying property transactions.
  • Global Compliance: Hong Kong has enacted the Global Minimum Tax (Pillar Two) and a Foreign-Sourced Income Exemption (FSIE) regime to meet international standards.

For a foreign executive considering a move to Asia, the choice between Mainland China and Hong Kong is more than a lifestyle decision—it’s a fundamental financial calculation. While China’s 2019 tax reforms reshaped the cost of expatriate life, Hong Kong’s stable, low-tax regime presents a compelling and often overlooked alternative. Understanding the stark contrast between these two systems is crucial for any professional or business planning their future in the region.

The Hong Kong Alternative: A Stable, Low-Tax Harbour

Unlike Mainland China’s progressive reforms, Hong Kong’s tax framework is defined by its simplicity, predictability, and low rates. For expatriates and businesses, this translates into clear financial planning and significant take-home pay retention. The system is built on a territorial basis, meaning only income arising in or derived from Hong Kong is subject to tax.

Salaries Tax: Capped Rates and Generous Reliefs

Hong Kong’s salaries tax offers two calculation methods, with taxpayers liable to pay the lower amount. The progressive rates start at 2% and top out at 17%. Alternatively, income is taxed at the standard rate, which is 15% on the first HK$5 million of net income and 16% on any amount above that for the 2024/25 year. Crucially, this standard rate acts as a cap, ensuring tax liability never spirals unexpectedly.

📊 Example: A senior executive with a net chargeable income of HK$800,000 would pay approximately HK$115,000 in progressive tax. However, their tax is capped at the standard rate calculation (15% of HK$800,000 = HK$120,000), so they pay the lower progressive amount. This system provides certainty for high earners.

Substantial personal allowances further reduce the tax burden. For the 2024/25 year, these include a basic allowance of HK$132,000, a married person’s allowance of HK$264,000, and a child allowance of HK$130,000 per child. Additional deductions are available for Mandatory Provident Fund (MPF) contributions (max HK$18,000), approved charitable donations (up to 35% of income), and domestic rent (max HK$100,000).

Profits Tax: A Business-Friendly Two-Tier System

For corporations and unincorporated businesses, Hong Kong’s profits tax is highly competitive. The two-tiered system taxes the first HK$2 million of assessable profits at a reduced rate, with the remainder taxed at the standard rate.

Entity Type Rate on First HK$2m Rate on Remainder
Corporation 8.25% 16.5%
Unincorporated Business 7.5% 15%
💡 Pro Tip: Only one entity within a group of connected corporations can elect for the two-tiered rates. Careful group structuring is essential to optimise which company claims the beneficial rate on its first HK$2 million of profits.

Navigating Hong Kong’s Modern Compliance Landscape

While Hong Kong’s core tax rates remain attractive, the jurisdiction has implemented significant reforms to align with global standards. Understanding these is non-negotiable for international businesses and high-net-worth individuals.

1. The Foreign-Sourced Income Exemption (FSIE) Regime

Effective from January 2023 (expanded in January 2024), the FSIE regime targets multinational enterprises. It subjects four types of foreign-sourced income received in Hong Kong by multinational entities to profits tax: dividends, interest, disposal gains, and intellectual property income. Exemption is available if the taxpayer meets specific economic substance requirements in Hong Kong for the relevant activities.

⚠️ Important: The FSIE regime represents a major shift. Holding companies with passive income must now demonstrate adequate staffing, expenditure, and decision-making in Hong Kong to claim tax exemptions on foreign-sourced income. Failure to meet the substance requirements can lead to a 16.5% tax charge.

2. The Global Minimum Tax (Pillar Two)

Hong Kong has formally enacted the OECD’s Global Minimum Tax rules. As of 6 June 2025, with effect from 1 January 2025, large multinational enterprise (MNE) groups with consolidated global revenue of EUR 750 million or more will be subject to a 15% minimum effective tax rate in Hong Kong. The rules include an Income Inclusion Rule (IIR) and a domestic Hong Kong Minimum Top-up Tax (HKMTT).

3. Family Investment Holding Vehicle (FIHV) Regime

For ultra-high-net-worth families, Hong Kong offers the FIHV regime. Qualifying family-owned investment holding vehicles can enjoy a 0% tax rate on profits from qualifying transactions. To qualify, the vehicle must have assets under management of at least HK$240 million and maintain substantial activities in Hong Kong, providing a tax-efficient wealth management hub.

Property & Stamp Duty: A Simplified Market

A major differentiator for Hong Kong is its treatment of property. Property tax is levied at 15% on the net assessable value (annual rent minus rates, with a 20% statutory allowance for repairs). More significantly, the government abolished all market-cooling stamp duties on 28 February 2024.

💡 Pro Tip: The abolition of the Special Stamp Duty (SSD), Buyer’s Stamp Duty (BSD), and New Residential Stamp Duty (NRSD) means residential property transactions are now subject only to the standard Ad Valorem Stamp Duty, which ranges from HK$100 to 4.25%. This significantly reduces the cost and complexity for both local and non-local buyers.

For stock transfers, the stamp duty remains at 0.1% payable by both the buyer and the seller, resulting in a total duty of 0.2% on the transaction value, plus a HK$5 fixed duty per instrument.

Key Takeaways

  • Maximise Personal Allowances: Ensure you claim all applicable salaries tax allowances and deductions, such as for MPF, mortgage interest, and domestic rent, to minimise your liability against the 15%/16% standard rate cap.
  • Plan for Substance: If your business receives foreign-sourced passive income, proactively structure your Hong Kong operations to meet the FSIE regime’s economic substance requirements to preserve tax exemptions.
  • Leverage Property Market Changes: The abolition of extra stamp duties makes Hong Kong residential property more accessible. Factor the simplified Ad Valorem Stamp Duty scales into your investment calculations.
  • Seek Professional Advice for Complex Structures: The interaction of the two-tier profits tax, FSIE, FIHV, and Global Minimum Tax rules requires expert navigation to ensure compliance and optimisation.

Hong Kong’s tax system continues to offer a compelling proposition of low rates and simplicity, but it is no longer a “set and forget” jurisdiction. The introduction of global anti-avoidance standards means strategic planning is essential. For expatriates and businesses comparing locations in Asia, Hong Kong’s combination of fiscal efficiency, modern compliance framework, and recent property market liberalisation presents a robust and attractive long-term base.

📚 Sources & References

This article has been fact-checked against official Hong Kong government sources:

Last verified: December 2024 | For professional advice, consult a qualified tax practitioner. Note: This article provides a Hong Kong perspective for comparative purposes and does not constitute advice on Mainland China tax law.

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