Hong Kong · Policy & practice

Hong Kong eases holding-company rules under New CIES

Holding companies no longer face a six-month wait before the investment assessment. They still need qualifying ownership, family-office management and Hong Kong operations, while the applicant's asset-holding period is unchanged.

Edited by Frank ChangSources checked: 7 October 2026Published: 7 October 2026

Central, Hong Kong© 2026 Conatus Mobility

Hong Kong's New Capital Investment Entrant Scheme allows applicants to hold eligible investments through a qualifying private company. From 1 March 2026, companies used for the investment requirements assessment no longer need to have been established for a minimum period. The change, announced on 2 March, admits companies less than six months old.[1]

For families with an office already in place, or building a family investment structure, the change makes it easier to bring the scheme's investments under the same management. The company must still meet conditions on ownership, permitted use, management and Hong Kong operations. Incorporation is only the starting point, and the immigration application remains a personal one.[2]

Which company structures qualify?

Under paragraph 1.12 of the Scheme Rules, the holding company must be incorporated or registered in Hong Kong under the Companies Ordinance, wholly owned by the applicant or entrant, and used exclusively for transactions in permissible investment assets. It must qualify before the investment-assessment application is submitted and continue to do so throughout the subsequent stay granted under the scheme.[2]

There are two permitted structures. The company can be a family-owned investment holding vehicle, or FIHV, as defined in section 5 of Schedule 16E to the Inland Revenue Ordinance. Alternatively, it can be a family-owned special purpose entity, or FSPE, under section 6, established beneath an FIHV. In that case, the parent FIHV must also be a private company incorporated or registered in Hong Kong and wholly owned by the applicant or entrant.[2]

These definitions leave limited scope to use a company simply because it is available. An ordinary trading business, a company shared with business partners, or a family company in which the applicant owns only a partial interest cannot be treated as eligible without the necessary changes and assessment.

The family office needs scale and local operations

The FIHV's activities in Hong Kong must meet requirements for at least two full-time employees and at least HK$2 million in annual local operating expenditure. New CIES allows those activities to be outsourced to an eligible single family office. In its guidance on the related substantial activities requirements, the Inland Revenue Department says staff employed and expenditure incurred by the office on the FIHV's behalf may be taken into account. Direct employment by the FIHV is therefore not always necessary, but the resources must remain commensurate with the activities. Outsourcing cannot be used to avoid the substance requirements.[2][4]

An FIHV established less than a year ago must reach the HK$2 million annual expenditure requirement by the end of its first year, and meet it in each subsequent applicable year.[2][3]

Management must be entrusted to an eligible single family office belonging to the applicant's family. Across that family's FIHV or FIHVs, the office must manage an aggregate net asset value of at least HK$240 million in assets specified in Schedule 16C.[3] This is a measure of the family's investment management scale, separate from the HK$30 million required of each New CIES applicant.

The office itself must qualify under the tax rules. The Inland Revenue Department's definition requires a private company normally managed or controlled in Hong Kong, providing services to specified persons of the family during the basis period for the relevant year of assessment. The service fees must be taxable. To meet the safe-harbour test, at least 75% of the office's assessable profits must come from services provided to specified persons of the family. Family members must ordinarily hold at least 95% of its beneficial interest, directly or indirectly.[4]

Where a qualifying charitable entity holds a stake, a statutory exception permits it to own up to 25%, with at least 75% held by the family and no more than 5% held by unrelated persons in total. This exception concerns the family office. The New CIES investment holding company remains subject to the separate requirement for full ownership by the applicant.[2][4]

The applicant's six-month holding period remains

The company's age and the applicant's asset-holding period belong to different assessments. Only the former has been relaxed. For the net asset assessment, applicants must still show absolute beneficial entitlement to at least HK$30 million in net assets or net equity throughout the six months before submitting that application. The current official page retains this condition and requires a Hong Kong practising CPA to assist with the fulfilment document.[5]

The investment assessment then examines whether the required permissible investments were made within the prescribed period. The minimum is still HK$30 million: at least HK$27 million in permissible financial assets or real estate, plus a separate HK$3 million contribution to the CIES Investment Portfolio. The change to the company's minimum age leaves both the amount and the permitted asset categories intact.[6]

Unless otherwise specified, the current rules extend the 1 March 2026 amendments to eligible private-company conditions to applications submitted before that date.[2] How they apply still depends on the stage of the application and the relevant requirements; the transitional provision does not confer eligibility on every asset acquired earlier.

Tax relief requires a separate assessment

Entrants may adjust how they hold investments during their permitted stay. The official FAQ allows permissible financial assets to be transferred from designated accounts in an individual's name to designated accounts in a qualifying holding company's name. The company must meet paragraph 1.12 on the transfer date and throughout the relevant subsequent stay. This provision covers transfers between those designated accounts; moving assets from an ordinary account into a company does not, in itself, make them eligible.[7]

Whether the FIHV qualifies for profits tax concessions remains a matter for the Inland Revenue Ordinance. The FAQ makes clear that meeting the New CIES company conditions carries no guarantee of tax relief.[7] The holding-company route broadens the choice of ownership and management structure, while leaving personal eligibility, investment compliance and tax requirements to be satisfied on their own terms.