Hong Kong Company Redomiciliation: Strategic Insights from the New Inward Regime

As global markets evolve and cross-border flexibility becomes essential, Hong Kong is making a decisive move to strengthen its position as a premier international business hub.

The draft of the Companies (Amendment) (No. 2) Bill 2024, gazetted on 20 December 2024, introduces a new inward company redomiciliation regime that allows foreign-incorporated businesses to relocate their domicile to Hong Kong without dissolving and re-establishing their legal identity. This new mechanism is poised to attract many global companies to the city.

This article explores the newly proposed Hong Kong Company Redomiciliation regime, introduced under the Companies (Amendment) (No. 2) Bill 2024. It outlines the eligibility criteria, application process, compliance requirements, tax implications, and the strategic advantages of relocating your company’s legal domicile to Hong Kong. 

What is Hong Kong Company Redomiciliation?

Redomiciliation enables a company incorporated in one jurisdiction to move its legal home to another jurisdiction—in this case, to Hong Kong—while preserving its legal identity, operational history, and corporate structure. This is an efficient alternative to winding up and re-incorporating, ensuring business continuity.

Objectives of the Regime

The primary aim is to boost Hong Kong’s global competitiveness by providing a streamlined, legally secure, and tax-neutral pathway for foreign businesses to integrate into Hong Kong’s regulatory and tax environment.

Who is Eligible?

According to the Companies Registry and legal experts:

• The original jurisdiction must allow outward redomiciliation.
• Eligible companies include:
  • Private and public companies limited by shares
  • Private and public unlimited companies with share capital
• No economic substance test (such as asset value or staff headcount) is required, making this regime more accessible than in many peer jurisdictions. 

Application Process

The Companies Registry oversees the redomiciliation process:

• Applications are typically processed within two weeks upon receipt of complete documentation.
• The company must present evidence of deregistration in its original jurisdiction upon approval within 120 days.
• Regulated entities such as insurers and banks must obtain prior approval from the Insurance Authority or Hong Kong Monetary Authority. 

Compliance Requirements Post Redomiciliation

Once redomiciled, companies must comply with the Companies Ordinance (Cap. 622), including:

• Annual returns and statutory filings
• Appointment of at least one local director
• Accounting and audit obligations are aligned with Hong Kong standards

Tax and Legal Considerations

The regime is designed to be tax-neutral:

• The Inland Revenue Department (IRD) confirms that transitional provisions will mitigate tax impact. 
• Redomiciled companies (except airlines) will generally be treated as Hong Kong tax residents, granting access to Hong Kong’s extensive network of tax treaties. 
• Companies may also be eligible for unilateral tax credits and tax exemptions during the transition. 

Also Read: Hong Kong Corporate Tax Guide 2025: Rates, Benefits, and Planning Strategies

Strategic Benefits

Redomiciliation to Hong Kong offers a suite of strategic advantages:

• Legal Continuity: Preserve your company’s legal history and contracts.
• Favourable Tax System: Low corporate tax rates, no capital gains tax, and no withholding tax on dividends or interest.
• Gateway to Asia: Unparalleled access to Mainland China and regional markets.
• Reputation and Stability: Transparent regulatory framework and world-class financial infrastructure.
• Ease of Doing Business: Efficient legal and professional services ecosystem.

Industry Use Cases

The redomiciliation regime unlocks strategic potential across a wide range of industries:

• Regional Headquarters & Holding Companies: Multinational corporations can centralise their management functions and financial operations in Hong Kong, benefiting from the city’s connectivity and business-friendly environment.
• Family Offices & Investment Vehicles: Wealth managers and investment entities can relocate to a jurisdiction known for regulatory clarity and confidentiality to gain improved access to financial services, clearer legal protections, and tax treaty benefits.
• Fintech, Startups & IP-Rich Businesses: Technology-driven and innovation-focused companies can benefit from robust IP protections, access to capital markets, and talent mobility. Redomiciling to Hong Kong also enhances credibility with investors and regulatory authorities.
• Insurance & Financial Services: For licensed institutions previously incorporated in offshore jurisdictions, redomiciliation provides an opportunity to reinforce operational legitimacy and regulatory compliance under the supervision of Hong Kong’s financial regulators.
• Professional Services & Consultancy Firms: Firms with regional clientele can enhance trust, visibility, and client acquisition by anchoring operations in one of Asia’s most reputable service economies.
• Asset Management & Private Equity: Fund structures and SPVs may leverage redomiciliation to simplify regional administration, optimise tax positioning, and access Hong Kong’s mature financial and legal infrastructure.

Where To Next?

Navigating a redomiciliation requires deep knowledge of cross-border regulations and practical execution. InCorp’s experts across Asia-Pacific can assist with:

• Eligibility assessment and strategic feasibility
• End-to-end compliance advisory and application support
• Tax and structuring optimisation
• Post-transition governance and administration

With the redomiciliation regime, Hong Kong sends a strong message of openness and adaptability. For established businesses looking to reinforce their presence in Asia, this is a timely gateway to one of the world’s most dynamic economies.

Speak to our advisors today to explore your redomiciliation potential and discover how InCorp can help you make a seamless move to Hong Kong.