Hong Kong family offices and the successor question

What Hong Kong has built for family offices

Since the Government's March 2023 policy statement on family offices, Hong Kong has assembled a coherent offer. The Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance 2023 applies a 0 per cent profits tax rate to qualifying transactions of a family-owned investment holding vehicle (FIHV) managed by an eligible single family office (ESFO), from the year of assessment 2022/23. The conditions are specific: at least HK$240 million of specified assets under management (with a look-back to the two preceding years if the current year falls short), at least 95 per cent beneficial ownership by family members (or 75 per cent where a charity holds up to 25 per cent), central management and control in Hong Kong, at least two qualified full-time employees and HK$2 million of operating expenditure in Hong Kong, and no more than 50 FIHVs per ESFO. InvestHK's FamilyOfficeHK team, the Network of Family Office Service Providers and the Hong Kong Academy for Wealth Legacy sit alongside. In September 2025 the Government announced that its target of 200 family offices established or expanded with InvestHK support had been met ahead of schedule, and the 2026 Policy Address commits to further enhancing the preferential regimes for funds, single family offices and carried interest.

The residence link is the New Capital Investment Entrant Scheme. Since 1 March 2025, investment made through a Hong Kong-incorporated private company wholly owned by the applicant, where that company is an FIHV or a family-owned special purpose entity under one, managed by an ESFO, counts toward the HK$30 million investment requirement. The net-asset look-back was shortened to six months at the same time. From 1 November 2026 qualifying financial assets must be transacted through designated accounts. The principal, their spouse or recognised partner and unmarried children under 18 may apply for residence, and seven years of continuous ordinary residence may support permanent residence.

The successor question

A family office is usually established with succession in mind, and the immigration structure does not follow the tax structure. The New CIES principal's dependants are limited to a spouse and unmarried children under 18. An adult son or daughter who will run the Hong Kong office in ten years has no derivative status at all. A minor child who arrives at 14 ceases to be a dependant at 18 and must hold some other permission to remain, or the residence clock stops.

The question families should ask at the outset is therefore: which member of the next generation will acquire Hong Kong residence in their own right, on which route, and when does their seven years start? There are four realistic answers.

• Study, then the IANG. A child who completes a full-time, locally accredited degree in Hong Kong may apply within six months of graduation for 24 months of condition-free stay, extended on a degree-level job or a business. Lawful study is residence for a settled purpose, so the seven-year count can begin at enrolment. This is the most common successor path and the cheapest to document.
• The Top Talent Pass Scheme. A graduate of a listed university with three years' experience (Category B), or a recent graduate within the quota (Category C), may enter without a job offer. Extension requires degree-level employment or an operating business, so the family office itself must provide a real role.
• Employment by the family office. The ESFO must have at least two qualified full-time employees in Hong Kong for the concession, and a genuine investment or operational role for a family member may be sponsored under the General Employment Policy or ASMTP. ImmD will test the vacancy, the person's qualifications, local unavailability and market pay as for any other hire. A title without duties, or a package set for immigration rather than for the work, invites refusal.
• A separate New CIES application. An adult child with HK$30 million of net assets held for six months may apply in their own right. This is a capital decision as much as a residence one.

Substance, again

Every one of those routes is renewed on substance and ends in the same seven-year test, which asks where the person habitually lives, whether they work for a Hong Kong employer, where their spouse and minor children are, and whether they have paid tax. A successor who holds a Hong Kong permission while living in Shanghai, Singapore or London will reach year seven with nothing to verify. The tax regime, by contrast, is indifferent to where the family members live so long as the FIHV's central management and control and the two employees are in Hong Kong. Families frequently discover that the structure qualified for the concession while nobody in the family qualified for the right of abode.

The two can be aligned. If the family office is to be the successor's employer, the successor's role should be real from the beginning: a documented investment mandate, a reporting line to the principal or an external CIO, market pay, MPF and tax. That role satisfies ImmD at the GEP stage and at each extension, generates the salaries tax record the right-of-abode assessment considers, and, if income exceeds HK$2 million, opens the top-tier stream with five years on time limitation only.

Tax residence and the family's other bases

Hong Kong's territorial system means the successor's Hong Kong salary is taxed at progressive rates up to 17 per cent or at the standard rate of 15 per cent on the first HK$5 million of net income and 16 per cent above, and that dividends and capital gains are outside the net. That is attractive, but it is one side of a ledger. A successor who is also tax resident elsewhere, holds another country's permanent residence or long-term permit, or has a spouse and children abroad, should take advice on the interaction before signing the ROP146 declaration that Hong Kong is their only place of permanent residence. WG coordinates this analysis with the family's tax and legal advisers; it does not give tax advice.

Sequencing for a family

A workable sequence is: establish the ESFO and FIHV and confirm the tax concession with the family's advisers; bring the principal and minor children in under the New CIES, enrolling the children in Hong Kong schools at once; place the designated successor on a route that starts their own clock, whether study, the TTPS or a genuine role in the family office; keep each family member's travel log separately; plan the 18th birthday of each child in advance; and file each right-of-abode application in Hong Kong after the respective seventh anniversary. The family office holds the capital; the residence is earned one person at a time.