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The bill for inward re-domiciliation of non-Hong Kong incorporated or domiciled companies to re-domicile to Hong Kong has been enacted into law
On 23 May 2025, the Companies (Amendment) (No. 2) Ordinance 2024 (the Ordinance) was gazetted to provide an inward re-domiciliation regime in Hong Kong.
The regime will enable non-Hong Kong incorporated or domiciled companies to transfer their domicile (essentially their place of incorporation) to Hong Kong, while preserving their legal identity and maintaining their business continuity.
This alert focuses on the committee stage amendments (CSAs) to the bill and the Government’s clarifications on the tax-related issues during the legislative process.
Please refer to our previous tax alert for the detailed provisions of the transitional tax rules and the application procedures in relation to the regime.
Clients who wish to explore the pros and cons of re-domiciling their non-Hong Kong incorporated or domiciled companies to Hong Kong or to understand more about the issues discussed in this alert can contact their tax executive.
Download this Hong Kong Tax Alert（简体中文）