Hong Kong Unveils Re-domiciliation Scheme to Attract Global Enterprises

On 14 May 2025 the Legislative Council of the Hong Kong Special Administrative Region (Hong Kong SAR) enacted the Amendment Ordinance 2025 (the Ordinance), introducing a streamlined inward company re-domiciliation scheme. Under the Ordinance, foreign-incorporated entities can transfer their domicile to Hong Kong SAR while preserving their corporate identity and operational continuity, provided they satisfy a limited set of statutory requirements.

The legislation aligns with the Hong Kong SAR Government’s broader strategy to attract global enterprises and capital, fostering economic growth by offering businesses greater flexibility. It provides a practical solution for companies incorporated abroad with significant operations in Hong Kong that wish to re-domicile seamlessly.

Hong Kong’s free-market environment, competitive tax regime, and well-established legal system make it an attractive jurisdiction for businesses seeking stability and efficiency. The amendment unlocks a reasonably painless route for businesses transitioning from offshore to mid-shore, benefiting from Hong Kong’s low profits tax rates, territorial tax system and absence of capital gains or dividend taxes.

Key Provisions of the Re-domiciliation Scheme

• Eligible Applicants – Non-Hong Kong-incorporated companies from jurisdictions that permit outbound re-domiciliation such as the Cayman Islands, the British Virgin Islands, Bermuda, Delaware and Singapore.
• Minimum Incorporation Period – Companies must have been incorporated for at least one financial year prior to application.
• Continuity of Operation – The re-domiciliation process ensures that a company’s assets, entitlements, duties, and liabilities, along with associated legal and contractual arrangements, remain unaffected.
• Tax Considerations – Should profits be subject to taxation in the original jurisdiction post-re-domiciliation, the Hong Kong SAR Government will provide unilateral tax credits to mitigate double taxation. Re-domiciled companies will be deemed incorporated in Hong Kong SAR.
• Regulatory Compliance – Re-domiciled companies shall enjoy rights equivalent to those of Hong Kong-incorporated companies of the same category and must adhere to applicable statutory obligations within Hong Kong SAR.

Effective 23 May 2025, the Ordinance will come into force, and the re-domiciliation scheme will begin accepting applications. The Companies Registry will launch a dedicated online section providing comprehensive application procedures and relevant guidance. Upgrades to the Integrated Companies Registry Information System will facilitate efficient processing of re-domiciliation applications.

Navigating the Transition

Hong Kong’s new re-domiciliation scheme presents a valuable opportunity for businesses seeking a seamless transition into one of the world’s most dynamic financial hubs. While the process is designed to be straightforward, ensuring full compliance and operational continuity requires expertise. Marbury’s experienced team provides tailored corporate advisory, regulatory and company secretarial services, helping businesses navigate the complexities of re-domiciliation with confidence. Contact your usual Marbury relationship manager or info@marburys.com to learn more about how Marbury can support your transition.