Tax Residency & Special Tax Regimes

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Hong Kong is internationally renowned for its tax neutrality and investor-friendly fiscal architecture. The territory does not impose any taxes on foreign-sourced income, capital gains, dividends, or inheritance.

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Under Hong Kong law, an individual becomes a tax resident if they ordinarily reside in Hong Kong or stay for more than 183 days in a tax year, or more than 300 days over two consecutive years. For CIES investors, tax residency is elective: if they wish to use Hong Kong as a domicile for tax purposes (e.g., to access its tax treaty network or justify offshore company residency), they must meet one of these criteria.

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There is no formal non-dom regime like Portugal or the UK. However, the territorial basis of taxation allows for similar strategic outcomes: foreign dividends, trust income, capital gains, and foreign employment income are exempt from tax if not sourced from within Hong Kong.

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Ultra-high-net-worth families often use family offices, private trust companies, or offshore SPVs to channel returns and structure inheritance. Hong Kong does not tax these vehicles if they do not derive income from Hong Kong operations.

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