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Hong Kong companies

Hong Kong profits tax: rates, territorial basis and offshore claims

Hong Kong taxes only profits arising in or derived from Hong Kong. Corporations pay 8.25% on the first HKD 2 million of assessable profits and 16.5% on the rest. There's no VAT, no tax on dividends and no capital gains tax, but foreign-sourced passive income now needs economic substance to stay exempt.

The rates

Assessable profits Corporations Unincorporated businesses
First HKD 2,000,000 8.25% 7.5%
Remainder 16.5% 15%

Only one company in a group of connected entities can claim the lower first-tier rate.

The territorial principle

Hong Kong taxes profits arising in or derived from Hong Kong. Where the profit-producing activities happen decides the source. A company whose trading operations genuinely take place outside Hong Kong can file an offshore claim, which the Inland Revenue Department reviews closely and which requires good documentation.

Foreign-sourced income exemption (FSIE)

Since 2023, certain foreign-sourced passive income received in Hong Kong by companies in multinational groups, such as dividends, interest, IP income and disposal gains, is only exempt if conditions such as economic substance in Hong Kong are met.

What Hong Kong doesn’t tax

  • No VAT or GST
  • No tax on dividends paid
  • No capital gains tax (subject to FSIE for some groups)

Compliance

Companies file an annual profits tax return with audited financial statements. Our Hong Kong company formation service can include accounting and tax filing, and our holding structure advice covers dividends from a mainland WFOE.

Reviewed by Choi & Partners · 3 October 2026. This page is general information, not legal advice.
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