The Tax Advantage of Hong Kong's Family Office Regime
Hong Kong has established one of Asia's most competitive family office tax frameworks — with the FIHV exemption under s.13P-13Q, 0% concessionary carried interest for resident SFOs, no CGT, and the FSIE participation exemption for dividends. Our specialists help UHNW families qualify for and maintain these significant structural advantages while planning seamlessly across generations.
Family Office Tax Advisory
Hong Kong has established one of Asia's most competitive family office tax frameworks — with the FIHV exemption under s.13P-13Q, 0% concessionary carried interest for resident SFOs, no CGT, and the FSIE participation exemption for dividends. Our specialists help UHNW families qualify for and maintain these significant structural advantages while planning seamlessly across generations.
⚠ Critical: The FIHV Exemption Has Strict Qualifying Conditions — Non-Compliance Is Retroactive
The Family Investment Holding Vehicle (FIHV) exemption under s.13P-13Q of the IRO provides significant tax relief, but imposes strict conditions: minimum AUM of HK0 million, local expenditure requirements (minimum HKM/year on HK-based operational costs), investment scope limitations, and qualified management entity requirements. Failing any condition during any year retroactively invalidates the exemption for that entire year, creating an unexpected and potentially large tax liability.
Are you facing these tax issues?
FIHV Exemption Qualification & Maintenance
The FIHV exemption requires careful ongoing compliance: HK0M AUM threshold, HKM minimum local expenditure, and portfolio within permitted asset classes. One year's non-compliance retroactively removes the exemption for that year.
Passive Income Under FSIE — Dividends & Interest
Since 2023, FSIE requires entities receiving passive income (dividends, interest, royalties) to demonstrate genuine economic substance or meet participation exemption conditions. Family office holding companies must structure carefully or face 16.5% tax.
Cross-Border Asset Holdings & Multi-Jurisdiction Tax
UHNW families typically hold assets across HK, UK, US, Singapore, and offshore structures. Without integrated planning, families routinely pay tax in multiple jurisdictions on the same income.
Succession & Generational Wealth Transfer
HK has no estate duty, but family members may hold assets in jurisdictions with 40%+ inheritance tax. Without proactive cross-border succession planning, UHNW families face tax bills of tens of millions on wealth transfer events.
Who This Service Is For
Dedicated SFOs managing assets exclusively for one UHNW family, seeking FIHV exemption and governance structuring.
MFOs managing assets for multiple unrelated families — more complex qualification but significant economies of scale.
Family-controlled investment companies not formally structured as family offices but seeking equivalent tax efficiency.
Property-owning families restructuring to separate investment from operating assets and optimise succession planning.
Families with members in multiple jurisdictions requiring integrated cross-border tax and succession planning.
What We Cover
FIHV Exemption Structuring (s.13P-13Q)
Qualification assessment, holding entity structuring, and ongoing compliance monitoring to maintain the FIHV exemption.
FSIE Passive Income Planning
Structure dividend, interest, and royalty income flows through qualifying participation arrangements under the FSIE regime.
Carried Interest Concessionary Rate
Qualify for the 0% profits tax rate on carried interest under s.14C-14D for HK-resident single family offices.
Trust Structuring & Governance
Advise on discretionary, fixed, purpose, and charitable trusts for asset protection, succession, and governance objectives.
Succession Planning & Estate Structuring
Integrated cross-border succession plans maximising HK's no-estate-duty environment while managing overseas exposure.
Simple, efficient, professional
Family Wealth Mapping & Tax Exposure Assessment
Comprehensive mapping of the family's assets across all jurisdictions — HK equities, real estate, offshore accounts, trust structures — identifying tax exposure and opportunities.
Weeks 1-3FIHV Qualification Analysis & Structure Design
Detailed analysis of FIHV eligibility against HK0M AUM, HKM expenditure requirement, portfolio composition, and management entity criteria.
Weeks 3-8Implementation & Legal Execution
Coordinate trust deeds, holding company establishment, asset transfers, and FSIE-compliant income flow arrangements with solicitors and custodians.
Months 3-6Annual FIHV Compliance & Tax Management
Annual compliance review of all exemption conditions, tax return preparation, FSIE reporting, and ongoing advisory on new transactions.
OngoingReal results for real clients
Single family office — HK0M AUM qualified for FIHV
- HK0M AUM, primarily HK equities and PE interests
- Previously paying 16.5% on HK.5M annual returns
- Minor adjustments needed to formalise management entity
Property family — holding company restructuring for succession
- 7 commercial properties worth HK0M held personally
- Direct transfer stamp duty exposure of HK.8M
- Restructured into holdco — share transfers at 0.2% stamp duty
Free Expert Consultation
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- Free 30-min initial consultation
- Senior CPA assigned to your case
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Why Choose TAX.hk
Deep HK Tax Expertise
Our CPAs have 15+ years of HK tax experience and keep current with every IRD update.
Transparent Fixed Fees
No hourly billing surprises. Know your cost upfront before we start.
24-Hour Response
We respond to all enquiries within one business day. Urgent cases within 4 hours.
Strict Confidentiality
All client information is held under strict professional duty of confidentiality.
Frequently Asked Questions
Quick answers to your questions
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This page provides general information only. For advice specific to your situation, please consult a qualified Hong Kong tax professional.