By Family Office Institute Hong Kong (FOIHK) · Published: 2026-07-30
Under Hong Kong’s FIHV regime, eligible Family-owned Investment Holding Vehicles (FIHVs) managed by a single family office in Hong Kong pay a 0% profits tax rate on qualifying transactions. The concession was legislated in 2023 and applies retroactively from 1 April 2022. This guide summarises the regime as of 30 July 2026 — it is general information, not tax advice.
What is an FIHV?
A Family-owned Investment Holding Vehicle is an entity (in or outside Hong Kong) that is at least 95% owned by one or more individuals of a single family and is used to hold and manage the family’s investments. The regime lets such vehicles elect into a profits-tax concession when they are managed by an eligible single family office in Hong Kong.
The qualifying conditions
| Condition | Requirement |
|---|---|
| Ownership | ≥ 95% owned by members of a single family (75% where charitable entities are involved) |
| Management | Managed by an eligible single family office; central management and control in Hong Kong |
| Minimum AUM | HK$240 million (≈ US$30M) in specified assets |
| Substance | ≥ 2 qualified full-time employees in Hong Kong |
| Spending | ≥ HK$2 million annual operating expenditure in Hong Kong |
| Tax rate | 0% on qualifying transactions in specified assets |
What assets qualify
The concession covers transactions in specified asset classes — broadly, shares, stocks, debentures, bonds, funds and similar securities, including qualifying private-company investments. Direct Hong Kong real estate trading and certain other activities fall outside the concession, so most families hold operating businesses and property outside the FIHV.
FIHV in context: LPF, OFC and carried interest
- Limited Partnership Fund (LPF): Hong Kong’s limited-partnership fund vehicle (since 2020) — often used underneath or alongside an FIHV for private investments.
- Open-ended Fund Company (OFC): corporate-form fund vehicle suited to more liquid strategies.
- Carried interest concession: a separate Hong Kong concession providing favourable treatment for qualifying private-equity-style carried interest received in Hong Kong.
Compliance reality
The concession is elective and evidence-based: families should expect to document family ownership, the SFO’s management activities, the employee and expenditure substance tests, and keep annual elections and filings current. Most families work with Hong Kong tax counsel and a corporate services provider from day one.
Further reading
Last updated: 2026-07-30