In today’s ever-evolving corporate landscape, businesses are rethinking where they operate from. International tax reforms, economic substance rules, and regulatory changes have made it less attractive to stay incorporated in certain offshore jurisdictions. Hong Kong, with its pro-business legal structure and reputation as a leading international financial hub, has responded strategically with its new re-domiciliation regime, effective 23 May 2025.
This regime allows foreign companies to transfer their place of incorporation to Hong Kong without needing to dissolve or reincorporate. For international firms seeking stability, market access, and tax certainty, this development is more than administrative—it’s a game-changer.
Before this reform, foreign companies wishing to redomicile had to consider complex alternatives like asset transfers or court-sanctioned schemes. Now, they can retain legal identity, preserve continuity, and enter the Hong Kong market on much more favourable terms.
If you’re looking to realign your global structure, simplify operations, and move into a more secure regulatory environment—this is the time to act.
What is Company Redomiciliation in Hong Kong?
Redomiciliation is the process through which a company changes its legal jurisdiction without interrupting its existence. Under Hong Kong’s new regime, eligible foreign companies may apply to the Companies Registry to become companies incorporated in Hong Kong.
Once approved, the entity becomes a Hong Kong company with the same rights and obligations as if it had always been incorporated there. Notably, the company retains its assets, contracts, licenses, and liabilities without interruption.
Why Redomicile to Hong Kong in 2025 Under the New Regime?
The new redomiciliation regime launched on 23 May 2025 presents a timely solution for companies facing global compliance pressures, especially those incorporated in offshore or low-substance jurisdictions. Previously, migrating a company’s legal base to Hong Kong required restructuring, asset transfers, or creating a subsidiary—processes that were often expensive and disruptive. Now, the 2025 regime allows eligible foreign companies to move their place of incorporation directly to Hong Kong without losing legal identity or disrupting operations.
This regime matters more than ever due to:
- OECD’s global minimum tax (Pillar Two), reducing the benefit of zero-tax jurisdictions
- Economic substance rules requiring costly local presence in offshore locations
- Heightened investor scrutiny around transparency, governance, and jurisdictional credibility
By Redomiciling to Hong Kong under the new regime, companies can:
- Retain their legal history without winding up or reincorporating
- Avoid duplication of tax and reporting obligations
- Comply easily with international norms while operating from a reputable hub
- Leverage Hong Kong’s extensive treaty network, financial infrastructure, and proximity to Mainland China
For businesses looking to future-proof their structure, protect shareholder value, and maintain operational continuity in Asia, this regime is a strategic pathway—not just an administrative update. It reflects Hong Kong’s commitment to remain a top-tier corporate jurisdiction amid changing global expectations.
What are the Benefits of Hong Kong’s Redomiciliation Regime?
Hong Kong’s 2025 redomiciliation framework offers a compelling list of advantages to foreign companies seeking continuity, simplicity, and strategic growth:
| Benefit | Explanation |
|---|---|
| Continuity of legal identity | No need to dissolve or reincorporate. Legal history is preserved. |
| Time and cost savings | Avoids restructuring, asset transfers, or subsidiary creation. |
| Simplified tax environment | Territorial tax system; no capital gains tax or VAT. |
| No economic substance test | No local employee or physical presence requirement. |
| Strong legal and regulatory framework | Backed by the Companies Ordinance (Cap. 622). |
| Investor and market credibility | Seen as a premium jurisdiction with international standards. |
What Company Types are Eligible for Redomiciliation to Hong Kong?
Only companies with the following structures are eligible:
- Private company limited by shares
- Public company limited by shares
- Private unlimited company with share capital
- Public unlimited company with share capital
Additional requirements include:
- The company must have completed at least one full financial year
- It must not be in liquidation or facing winding-up proceedings
- The company must be solvent and able to pay debts within the next 12 months
- The laws of the original jurisdiction must permit redomiciliation
- The application must be made in good faith, with no intent to defraud creditors
- Where required, shareholder approval must be secured (typically 75% vote)
What are the Key Requirements to Apply for Company Redomiciliation in Hong Kong?
To apply, a company must prepare the following:
- Form NNC6 – Application for Redomiciliation
- IRBR5 Form – Notice to Business Registration Office
- Certified incorporation documents from the original jurisdiction
- Legal opinion confirming eligibility from a lawyer in the home jurisdiction
- Audited financial statements, no older than 12 months
- Proposed Articles of Association for Hong Kong
- Board certificate confirming solvency and statutory compliance
- Member resolution (if required by original laws or company constitution)
Applications must be submitted to the Hong Kong Companies Registry, either online or in hard copy.
What are the Government Fees in the Redomiciliation Process?
When applying for redomiciliation to Hong Kong, companies are required to pay statutory government fees to the Companies Registry. These fees differ based on how the application is submitted:
| Submission Type | Application Fee | Certificate of Re-domiciliation Fee |
|---|---|---|
| Online | HK$1,030 | HK$5,020 |
| Paper | HK$1,145 | HK$5,580 |
These are statutory fees and do not include professional service charges, legal opinion costs, or accounting fees. For more information, check the Guide on Company Re-domiciliation
What Post-approval Steps Must Re-domiciled Companies Follow in Hong Kong?
After the Companies Registry issues the Certificate of Redomiciliation, the company must:
- Submit evidence of deregistration in its previous jurisdiction within 120 days
- File updated shareholding information and director consents within 15 days
- Register any outstanding charges on assets within one month
- Maintain a registered office in Hong Kong
- Appoint a local company secretary
- Comply with all provisions under the Companies Ordinance, including annual filing obligations.
Failure to follow through can result in the revocation of the company’s re-domiciled status.
What are the Tax Implications of Redomiciling to Hong Kong?
Hong Kong operates on a territorial source principle—only income sourced within Hong Kong is taxed. There is no capital gains tax, withholding tax, or VAT.
| Tax Aspect | Impact |
|---|---|
| Profits Tax | Only applies to income earned in Hong Kong. |
| Stamp Duty | Not triggered by the re-domiciliation process |
| Pre-domicile Tax | No retrospective effect unless the business was already carried out in Hong Kong |
| Double Tax Relief | Credit available for tax already paid in the original jurisdiction. |
Relevant guidance is available under the Inland Revenue Ordinance (Cap. 112).
How does Redomiciliation in Hong Kong Compare to Other Jurisdictions?
| Jurisdiction | Allows Outward Re-domiciliation | Substance Requirements | Ease of Re-domiciling |
|---|---|---|---|
| Hong Kong | No | No | High |
| Singapore | No | Yes | Not permitted |
| Cayman Islands | Yes | Yes | Moderate |
| UAE | Yes | Yes | Medium |
Hong Kong stands out for clarity, speed, and the absence of economic substance rules, making it ideal for holding companies and regional headquarters.
Conclusion
Hong Kong’s newly introduced re-domiciliation regime is not just a procedural tool—it’s a strategic business enabler. In an era where jurisdictions are tightening regulations and investors demand greater transparency, Hong Kong offers an attractive landing point.
With no need to wind up or restructure from scratch, and with straightforward eligibility rules, companies now have a cost-efficient way to retain their global identity while benefiting from Hong Kong’s legal and financial infrastructure.
Whether your firm is seeking regulatory consistency, a more advantageous tax position, or enhanced access to capital markets, the 2025 re-domiciliation regime answers that need. With guidance from experienced professionals like 3E Accounting, the path to relocation can be swift, compliant, and commercially rewarding.
Take the next step. Contact 3E Accounting today, and let’s plan your seamless transition into Hong Kong.
Redomicile Your Company in Hong Kong
Ensure compliance, preserve your legal identity, and gain market access. Enquire with 3E Accounting to get started.
Frequently Asked Questions
Yes, if your offshore company meets Hong Kong’s eligibility criteria and the original jurisdiction permits outward re-domiciliation.
Once all documents are in order, it typically takes 2 to 3 weeks for approval by the Companies Registry.
No, but you must maintain a registered office and comply with director disclosure requirements under the Companies Ordinance.
Your redomiciliation in Hong Kong may be revoked if you fail to provide deregistration proof within 120 days.
Yes. Business registration with the Inland Revenue Department is included via a one-stop process during application.
No. The original company continues seamlessly but must be deregistered in its previous jurisdiction within 120 days post-approval.
Abigail Yu
Author
Abigail Yu oversees executive leadership at 3E Accounting Group, leading operations, IT solutions, public relations, and digital marketing to drive business success. She holds an honors degree in Communication and New Media from the National University of Singapore and is highly skilled in crisis management, financial communication, and corporate communications.
