A structure for your cross-border business.
LMY helps assess overseas company formation arrangements for cross-border ownership, international trade and overseas operations.
Overseas incorporation does not automatically exempt a business from Hong Kong tax. Its actual business circumstances must be assessed.
View incorporation and annual fees ↓
Overseas company incorporation and annual fees
| Jurisdiction | Incorporation / first-year fee | Annual fee from year two |
|---|---|---|
| British Virgin Islands (BVI) | From HK$18,000 | From HK$12,000 |
| Cayman Islands | From HK$28,000 | From HK$28,000 |
| Other overseas countries / jurisdictions | Contact LMY Consulting directly for a quotation | |
BVI and Cayman Islands incorporation packages include: government registration fees, a first-year registered address, a company kit, CDD / SCR and a Certificate of Incumbency; up to two shareholders and directors.
Additional shareholders and directors incur extra charges. Please contact our customer service team for details.
The above prices are for reference only. Please contact the LMY Consulting customer service team to confirm the actual prices.
Tax and accounting comparison
| Item | HK Unlimited (sole proprietor / partnership) | HK Limited Company | Offshore Company* |
|---|---|---|---|
| Separate legal entity | ✕ | ✓ | ✓ usually |
| Limited liability | ✕ unlimited liability | ✓ generally limited to unpaid share capital | ✓ subject to incorporation law |
| Keep sufficient HK business records for at least 7 years | ✓ | ✓ | ✓ where carrying on business in HK |
| HK statutory audit (general position) | ✕records still required | ✓ generally required (see exceptions below) | Depends on incorporation law and HK filing requirements |
| HK profits tax: first HK$2m of eligible assessable profits | 7.5% | 8.25% | Depends on source and entity type |
| HK profits tax: eligible assessable profits above HK$2m | 15% | 16.5% | Depends on source and entity type |
| Automatic HK tax exemption merely because it is “offshore” | ✕ | ✕ | ✕ |
| Generally suitable for | Low-risk, simple small businesses | Businesses needing limited liability, shareholders or stronger corporate standing | Cross-border structures requiring case-specific advice |
| Effective period: The Hong Kong two-tiered profits tax rates shown above apply from the year of assessment 2018/19 onwards (effective 1 April 2018). Rates apply to assessable profits, not turnover. Eligibility and connected-entity restrictions apply; where the two-tiered regime does not apply, the standard rates are 15% for unincorporated businesses and 16.5% for corporations. These standard rates apply from the year of assessment 2008/09 onwards (years of assessment commencing on or after 1 April 2008). Offshore tax treatment requires separate assessment. IRD: profits tax rates · Two-tiered regime and eligibility. | |||
Comparison scope and official references
The Hong Kong limited company column concerns private companies limited by shares; unlimited businesses mean sole proprietorships or general partnerships. The offshore column assumes a foreign limited-liability company, subject to its incorporation law.
Two-tiered rates apply to assessable profits, not turnover. Normally only one connected entity can elect for them. Corporate partners' shares of partnership profits attract the applicable corporate rates. The table excludes special concessions, personal assessment and minimum top-up taxes applicable to large multinational groups.
Statutorily dormant companies may qualify for audit exemption. Having no transactions or qualifying for simplified reporting does not itself remove the audit requirement. Hong Kong business records generally require at least seven years' retention.
References: IRD: two-tiered rates · Record keeping · CR: accounts and audit. Reviewed 14 September 2026; apply the rules to the relevant facts and assessment year.
*Subject to incorporation law and Hong Kong operations.
Existing foreign companies: documents for Hong Kong registration
- Certified incorporation certificate and constitutional documents
- Certified latest published accounts, where applicable
- Generally apply within one month of establishing a Hong Kong place of business, using NN1, IRBR2 and supporting certified documents, with Hong Kong authorized representative details
Foreign incorporation and Hong Kong tax
New incorporation documents depend on the chosen jurisdiction, entity and local agent. The Hong Kong registration list above is not a checklist for forming a new foreign company.
Hong Kong tax cannot be determined solely by incorporation location or where operations occur. Under FSIE, specified foreign-sourced interest, dividends, disposal gains and IP income received in Hong Kong by an in-scope MNE entity may be taxable unless the relevant exemption requirements are met. Certain large MNE groups also fall within minimum top-up tax rules.
Hong Kong introduced an inward company re-domiciliation regime on 23 May 2025. It is a separate option from registering a non-Hong Kong company, with its own eligibility and procedures.
CR: non-Hong Kong registration · IRD: FSIE · Minimum top-up tax · Re-domiciliation