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Corporate Structuring
Corporate Structuring

Hong Kong flagHong Kong

Asia's definitive family office hub — the 2026 FIHV 0% profits tax exemption expanded to partnerships, overseas real estate, precious metals and digital assets, with a simplified HK$240M AUM asset value threshold.

0% FIHV Tax (2026)
Tax Advantage
VCC + Family Office
Key Structure
HK$240M AUM
Key Benefit
Overview

Jurisdiction Overview

Hong Kong stands as Asia's premier financial capital and a dominant global sanctuary for wealth preservation, offering ultra-high-net-worth individuals, cross-border corporate groups, and elite family offices a highly sophisticated common-law jurisdiction. Positioned as the primary financial super-connector between mainland Chinese capital markets and global commerce, Hong Kong blends a robust judicial system based on English common law with a pro-business legislative landscape, making it an exceptional top-tier anchor for asset aggregation and international trade holding. The landmark 2026 Tax Reform Enhancements have dramatically expanded the scope of the Family-owned Investment Holding Vehicle (FIHV) regime — now encompassing direct and indirect equity interests in non-corporate entities (partnerships), overseas real estate, precious metals, and digital assets — while shifting the compliance test from a strict NAV calculation to a broader HK$240 million Asset Value requirement.

Structural Framework

Four Pillars of Structuring Excellence

Trusts & Foundations
Hong Kong Fiduciary Infrastructure
Discretionary Trust Structures
Governed under the robust Trustee Ordinance, a Hong Kong discretionary trust permits absolute asset segregation. By transferring the legal title of global equities, operating companies, and real estate to a professional trustee, settlors insulate those assets from future personal creditor risks, civil claims, and matrimonial disputes.
Insulation Against Forced Heirship & Corporate Foundation Hybrids
Local legislation embeds strong statutory firewall provisions — Hong Kong courts explicitly refuse to enforce foreign forced heirship rules or external judgments that conflict with the terms of a legally settled local trust. For civil law families, identical structural outcomes are routinely achieved by pairing private limited companies with specialized constitutional charters, restrictive bylaws, and private family councils.
Corporate Structuring
Private Limited Companies & VCC
Private Limited Companies
The benchmark vehicle for international trading desks and holding structures, a Hong Kong company offers rapid deployment, flexible share capital configurations, and exceptional corporate confidentiality. The Modern Re-Domiciliation Regime allows foreign companies to seamlessly transfer their legal seat to Hong Kong while fully preserving their historical track record and commercial contracts.
Bespoke Family Governance
We integrate class-based voting arrangements and operational succession clauses directly into your corporate Articles of Association. This effectively separates the day-to-day management of operating companies from ultimate beneficiary distributions, avoiding fragmented equity ownership across generations.
Banking & Financial Integration
Asia's Elite Banking Hub
Institutional Multi-Currency Portals
Establishing a verified Hong Kong corporate or trust structure unlocks immediate onboarding channels with top-tier private banks and elite wealth desks, fully optimized to execute high-volume multi-currency transactions, digital asset flows, and sophisticated global treasury functions.
Absolute Exchange Freedom
The jurisdiction operates with completely zero exchange controls, currency caps, or transaction-tracking barriers on cross-border outbound capital shifts. Corporate structures hold uninhibited autonomy to liquidate, redeploy, or distribute 100% of their business reserves and investment gains worldwide instantly.
Legal Tax Efficiency
2026 FIHV Regime
The Enhanced Family Office Concession (FIHV) 2026
Under the landmark 2026 Tax Reform Enhancements, Family-owned Investment Holding Vehicles (FIHVs) managed by an eligible single-family office enjoy a complete 0% profits tax exemption on their investment portfolios. The 2026 regulations expand the qualifying asset scope to include direct/indirect equity interests in non-corporate entities (partnerships), overseas real estate, precious metals, and digital assets.
Absolute Direct Tax Neutrality
Hong Kong enforces an absolute 0% tax on capital gains, 0% tax on global dividends, 0% tax on savings interest, and 0% inheritance or estate duties, completely eliminating domestic tax erosion for private asset holders. The simplified HK$240M AUM threshold — where shareholder loans are no longer deducted from asset value — allows families to fund their investment vehicles via flexible debt structures.
How We Assist

How Burbridge Capital
manages your structure

Bespoke Entity Architecture & Drafting
We manage the end-to-end design, drafting, and incorporation of Hong Kong Private Limited Companies, hybrid corporate foundation structures, and Discretionary Trusts, custom-tailoring your Articles of Association, protector veto protocols, and internal family office constitutions.
Family Office Regulatory Filings
Our dedicated compliance team directly handles your single-family office structural setups, meticulously preparing your documentation to satisfy the Substantial Activities Requirement (maintaining a minimum HK$2 million local operating spend and two full-time employees) to securely lock in your 0% FIHV profits tax exemptions.
Elite Private Bank Onboarding
We leverage our deeply rooted professional relationships across the most prestigious private banking institutions in Hong Kong to seamlessly guide your corporate and fiduciary files through rigorous AML, KYC, and UBO compliance tracks, activating your multi-currency capital accounts efficiently.
Continuous Fiduciary & Registry Support
Burbridge Capital provides complete, long-term corporate secretary management. We coordinate your annual return filings with the Companies Registry, manage your local registered office requirements, and oversee your bi-annual compliance reviews so your premium wealth protection structures remain permanently bulletproof.
FAQ

Frequently Asked Questions

What is the FIHV regime?+
The Family-owned Investment Holding Vehicle (FIHV) regime offers a 0% profits tax exemption on qualifying transactions, expanded in 2026 to cover partnerships, overseas real estate, and digital assets, provided the applicable AUM threshold is met.
What is the HK$240M AUM threshold?+
Family offices must generally demonstrate assets under management of at least HK$240 million to qualify for the simplified FIHV tax exemption pathway.
Why choose Hong Kong over Singapore for a family office?+
Hong Kong offers direct proximity to Mainland Chinese markets and capital, alongside a comparably sophisticated legal and financial infrastructure, making it a natural complement or alternative to a Singapore-based structure.

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