Family Office Tax Advisory

The Tax Advantage of Hong Kong's Family Office Regime

Hong Kong has established one of Asia's most competitive family office tax frameworks — with the FIHV exemption under s.13P-13Q, 0% concessionary carried interest for resident SFOs, no CGT, and the FSIE participation exemption for dividends. Our specialists help UHNW families qualify for and maintain these significant structural advantages while planning seamlessly across generations.

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HK0M Minimum AUM for FIHV exemption (s.13P-13Q)
0% Carried interest concessionary rate for qualifying SFOs
0% Capital gains tax on HK share disposals

Family Office Tax Advisory

Hong Kong has established one of Asia's most competitive family office tax frameworks — with the FIHV exemption under s.13P-13Q, 0% concessionary carried interest for resident SFOs, no CGT, and the FSIE participation exemption for dividends. Our specialists help UHNW families qualify for and maintain these significant structural advantages while planning seamlessly across generations.

⚠️

⚠ Critical: The FIHV Exemption Has Strict Qualifying Conditions — Non-Compliance Is Retroactive

The Family Investment Holding Vehicle (FIHV) exemption under s.13P-13Q of the IRO provides significant tax relief, but imposes strict conditions: minimum AUM of HK0 million, local expenditure requirements (minimum HKM/year on HK-based operational costs), investment scope limitations, and qualified management entity requirements. Failing any condition during any year retroactively invalidates the exemption for that entire year, creating an unexpected and potentially large tax liability.

주요 고민

다음과 같은 세무 문제로 어려움을 겪고 계신가요?

FIHV Exemption Qualification & Maintenance

The FIHV exemption requires careful ongoing compliance: HK0M AUM threshold, HKM minimum local expenditure, and portfolio within permitted asset classes. One year's non-compliance retroactively removes the exemption for that year.

⚠ Risk: Technical non-compliance → retroactive loss of entire year's exemption

Passive Income Under FSIE — Dividends & Interest

Since 2023, FSIE requires entities receiving passive income (dividends, interest, royalties) to demonstrate genuine economic substance or meet participation exemption conditions. Family office holding companies must structure carefully or face 16.5% tax.

⚠ Risk: FSIE non-compliance → foreign-sourced dividends taxable at 16.5%

Cross-Border Asset Holdings & Multi-Jurisdiction Tax

UHNW families typically hold assets across HK, UK, US, Singapore, and offshore structures. Without integrated planning, families routinely pay tax in multiple jurisdictions on the same income.

⚠ Risk: Uncoordinated planning → double taxation across jurisdictions

Succession & Generational Wealth Transfer

HK has no estate duty, but family members may hold assets in jurisdictions with 40%+ inheritance tax. Without proactive cross-border succession planning, UHNW families face tax bills of tens of millions on wealth transfer events.

⚠ Risk: No succession plan → catastrophic estate tax in UK/US/AU jurisdictions
대상

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Single family offices

Dedicated SFOs managing assets exclusively for one UHNW family, seeking FIHV exemption and governance structuring.

Multi-family offices

MFOs managing assets for multiple unrelated families — more complex qualification but significant economies of scale.

Private investment offices

Family-controlled investment companies not formally structured as family offices but seeking equivalent tax efficiency.

Property family groups

Property-owning families restructuring to separate investment from operating assets and optimise succession planning.

Cross-border UHNW families

Families with members in multiple jurisdictions requiring integrated cross-border tax and succession planning.

서비스 항목

서비스 내용

FIHV Exemption Structuring (s.13P-13Q)

Qualification assessment, holding entity structuring, and ongoing compliance monitoring to maintain the FIHV exemption.

AUM threshold monitoring, HKM expenditure planning, permissible asset review

FSIE Passive Income Planning

Structure dividend, interest, and royalty income flows through qualifying participation arrangements under the FSIE regime.

Participation exemption structuring, economic substance analysis, annual FSIE compliance

Carried Interest Concessionary Rate

Qualify for the 0% profits tax rate on carried interest under s.14C-14D for HK-resident single family offices.

Management entity structure, qualifying conditions compliance, annual reporting

Trust Structuring & Governance

Advise on discretionary, fixed, purpose, and charitable trusts for asset protection, succession, and governance objectives.

HK trust tax analysis, cross-border trust implications, CRS/AEOI reporting

Succession Planning & Estate Structuring

Integrated cross-border succession plans maximising HK's no-estate-duty environment while managing overseas exposure.

Multi-jurisdiction estate tax mapping, lifetime gifting, insurance-linked planning
진행 절차

간단하고, 효율적이며, 전문적인 서비스

1

Family Wealth Mapping & Tax Exposure Assessment

Comprehensive mapping of the family's assets across all jurisdictions — HK equities, real estate, offshore accounts, trust structures — identifying tax exposure and opportunities.

Weeks 1-3
2

FIHV Qualification Analysis & Structure Design

Detailed analysis of FIHV eligibility against HK0M AUM, HKM expenditure requirement, portfolio composition, and management entity criteria.

Weeks 3-8
3

Implementation & Legal Execution

Coordinate trust deeds, holding company establishment, asset transfers, and FSIE-compliant income flow arrangements with solicitors and custodians.

Months 3-6
4

Annual FIHV Compliance & Tax Management

Annual compliance review of all exemption conditions, tax return preparation, FSIE reporting, and ongoing advisory on new transactions.

Ongoing
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고객 성공 사례

실제 고객을 위한 실질적인 성과

FIHV Exemption

Single family office — HK0M AUM qualified for FIHV

HK.4M/yr 절감액
  • HK0M AUM, primarily HK equities and PE interests
  • Previously paying 16.5% on HK.5M annual returns
  • Minor adjustments needed to formalise management entity
"Our previous advisers said the FIHV exemption was complex and unlikely to apply. TAX.hk confirmed we qualified in three weeks. The annual saving is HK.4 million."
F
인증된 고객 FIHV Exemption
Property Restructuring

Property family — holding company restructuring for succession

HK.46M 절감액
  • 7 commercial properties worth HK0M held personally
  • Direct transfer stamp duty exposure of HK.8M
  • Restructured into holdco — share transfers at 0.2% stamp duty
"Restructuring our property portfolio before succession transfers saved us HK.4 million in stamp duty alone. TAX.hk handled the entire process seamlessly."
P
인증된 고객 Property Restructuring
★★★★★ 2,400+ 명 이상의 고객이 저희 팀을 신뢰합니다
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궁금증에 대한 빠른 답변

The Family Investment Holding Vehicle exemption under ss.13P-13Q of the IRO (effective April 2022) provides profits tax exemption on investment returns for qualifying family investment holding vehicles. Requirements include: AUM of at least HK0 million, minimum HK million annual operating expenditure in HK, investment activities within permitted asset classes, managed exclusively for one family, and management by a qualified investment manager. The exemption is applied year-by-year — failure to meet any condition retroactively removes the exemption for that entire year.
The FSIE regime (effective January 2023) removed the blanket exemption for offshore passive income. Specified foreign-sourced income (dividends, interest, royalties, disposal gains) received by a HK entity is now taxable unless the recipient meets the participation exemption (for dividends — 5% shareholding or HKM acquisition cost, minimum holding period) or demonstrates adequate economic substance. Family offices must structure dividend flows carefully to satisfy these conditions.
Under ss.14C-14D of the IRO, qualifying carried interest received by HK-resident SFOs is subject to a 0% concessionary profits tax rate. The carried interest must be received by a HK entity managing a qualifying fund, the fund must meet investment scale requirements, and the arrangement must be properly documented as a profit allocation rather than a service fee. We design the management entity structure and documentation to qualify.
Hong Kong does not require trust registration — there is no public register. For HK tax purposes, a trust is generally not itself taxable in the same way as a company. Taxation depends on whether the trustee carries on a business or holds investment assets. Distributions of capital gains are generally not HK taxable. However, overseas jurisdictions where beneficiaries reside may impose tax on trust income and distributions regardless of HK treatment.
HK abolished estate duty in 2006, removing domestic succession tax concerns. However, UK inheritance tax at 40% applies to UK-situated assets of non-domiciled individuals (e.g., a London flat worth GBP 5M creates a GBP 1.87M IHT exposure). US estate tax applies at up to 40% on worldwide assets of US persons. Planning around these exposures requires trust structures, lifetime gifting programmes, and careful domicile management.

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관련 서비스

Fund & REIT Tax Advisory PE/VC Fund Managers, REIT Managers & Family Offices
Carried Interest Tax Specialist Fund Managers & General Partners
Bond & Fixed Income Tax Specialist Bond Investors & Fixed Income Fund Managers
Private Equity Fund Tax Specialist PE Fund Managers & Limited Partners

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