IRD explains legislative bill for inward re-domiciliation for foreign incorporated or domiciled companies to redomicile to Hong Kong

On 20 December 2024, on the same day as the Companies (Amendment) (No. 2) Bill 2024 (the Bill) was gazetted, the Inland Revenue Department (IRD) posted on its website guidance on the interpretation of the various tax provisions of the Bill.

The provisions relating to the re-domiciliation requirements under the proposed amendments to the Companies Ordinance (amended CO) and other related enactments are essentially the same as discussed in our previous alerts, to which please refer. For ease of reference, a flow chart outlining the re-domiciliation procedures under the amended CO and the documents required for a re-domiciliation application are shown in Appendix I to this alert.

Adapted from the IRD’s guidance, this alert focuses on the transitional tax rules for a redomiciled non-Hong Kong company that before re-domiciliation has not carried on a trade, profession or business in Hong Kong and has carried on the trade, profession or business or another trade, profession or business in Hong Kong after the re-domiciliation.

Clients who have any views on the Regime can contact their tax executives so that we can convey the same to the Government in an appropriate manner.

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