Hong Kong family office mechanics
What a Hong Kong family office needs
Hong Kong's FIHV regime and the single family office it is managed by have specific thresholds, substance tests, and governance expectations. A working family office is the one whose structure, file, and family match all three.
Structural question
What does a working Hong Kong family office actually look like in the file, the substance, and the family decision?
The FIHV regime's net-asset-value minimum is a hard line; below it, the 0 percent concession is not available regardless of structure.
Two qualified full-time employees and the regime's annual operating expenditure threshold in Hong Kong are the visible part of the SFO substance; the invisible part is whether the SFO actually decides.
The 2026-27 Hong Kong Budget announced asset-management tax-concession enhancement proposals; rely on the current IRD FIHV rules until any amendment legislation and guidance are in force.
A regime that fits the file does not fit the family unless the family is ready to govern through a single family office instead of through the founder.
Family office file
FIHV at the regime's net-asset-value threshold, single family office managing the FIHV, family ownership 95 percent or more (with normal carve-outs), exempt scheme of investment, IRD-administered under the Inland Revenue Ordinance (Cap. 112) and the related FIHV provisions.
Single family office in Hong Kong, at least two qualified full-time employees, the regime's annual operating expenditure threshold, real investment-management decisions taken in Hong Kong.
Family charter or equivalent, decision authority, generational transition plan, banking corridor, trustee or holding structure where the family is ready, and refusal posture for jurisdiction shopping that has no real connection to family residence or assets.
What AGATE prepares
Map the family's actual assets against the current FIHV-qualifying scope, and separately track any 2026-27 Budget proposals until they are enacted and reflected in IRD guidance.
Plan the SFO's qualified employees, operating expenditure, premises, and decision authority so the substance test is met in practice and on paper.
Document family decisions, generational roles, dispute paths, and the relationship between the family, the SFO, and the FIHV.
Prepare the banking narrative for the FIHV and the SFO before opening accounts; the regime concession does not substitute for bank readiness.
Common questions
What is the FIHV minimum threshold?
The Family-owned Investment Holding Vehicle (FIHV) regime under Hong Kong's Inland Revenue Ordinance (Cap. 112) sets a minimum net-asset-value threshold, a minimum annual operating expenditure threshold in Hong Kong, and a minimum number of qualified full-time employees of the eligible single family office in Hong Kong.
The concession is a 0 percent profits tax rate on qualifying transactions for FIHVs that meet the substance tests.
What changed in the 2026-27 Budget?
The 2026-27 Hong Kong Budget announced proposals to enhance the asset-management tax regime, including broadening eligible asset classes for funds and single-family offices. Treat that as a policy direction until amendment legislation and IRD guidance are in force.
It does not lower the FIHV regime's net-asset-value threshold, annual operating expenditure requirement, or substance test for the managing single family office.
When does a family office actually start working?
It starts working when the family is governed by the structure rather than by the founder, when the SFO carries the investment decisions and the operating record, and when the banking file matches the regime claim.
A family office that has the thresholds and the structure but not the governance is a file with a tax concession, not a working office.
Official sources
- IRD FIHV Tax Concessionwww.ird.gov.hk/eng/tax/bus_fihv.htm
- Family Office Hong Kong (InvestHK)www.familyofficehk.gov.hk/
- Inland Revenue Departmentwww.ird.gov.hk/
Discuss your structure
If the family is at or approaching the FIHV threshold and the single family office, the operating expenditure, and the qualified employees are not yet in place, the 0 percent concession is not available regardless of asset value. Describe the family structure, the assets, and the SFO plan in a private enquiry.
No anonymous nominee work, no false substance, no bank misrepresentation, and no claim of universal asset protection.