How to Register a Family-owned Investment Holding Vehicle?
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Hong Kong Family Office Registration Guide
How to Register a Family-owned Investment Holding Vehicle?
Registering a Family-owned Investment Holding Vehicle (FIHV) in Hong Kong involves two distinct layers: the legal incorporation of the entity and the structuring required to qualify for Hong Kong’s 0% tax concession regime.
As of 2026, Hong Kong remains a premier hub for family offices, offering a streamlined process with no pre-approval required for tax exemptions, provided you meet the substance requirements.
1. Choose Your Legal Structure
Most families choose a Private Company Limited by Shares due to its clear legal framework and ease of banking. However, under the Inland Revenue Ordinance, an FIHV can also be a:
Trust (Common for succession planning).
Limited Partnership (Often used for co-investments).
Fund-like structure (e.g., Open-ended Fund Company or OFC).
2. The Registration Process (Corporate Route)
If you are incorporating a new Hong Kong company as your FIHV:
Step 1: Company Name Search: Ensure your name is unique via the Companies Registry e-Search.
Step 2: Appoint Key Officers:
Director: At least one natural person (can be a family member).
Shareholder: At least one (can be an individual or another holding entity).
Company Secretary: Must be a Hong Kong resident or a licensed HK trust/company service provider.
Step 3: Submit Documents: File Form NNC1 (Incorporation Form) and the Articles of Association.
Step 4: Business Registration: Upon incorporation, you will receive a Certificate of Incorporation and a Business Registration Certificate (BRC).
3. Qualifying for the 0% Tax Concession
To benefit from the dedicated tax regime for family offices (enacted in 2023), your FIHV must meet these 2026 criteria:
Requirement | Description |
Ownership | At least 95% beneficial interest must be held by members of the same family. |
Asset Threshold | Must manage a minimum of HK$240 million (approx. US$30.8M) in specified assets (securities, futures, etc.). |
Management | Must be managed by an Eligible Single Family Office (SFO) in Hong Kong. |
Substance | Must employ at least 2 qualified full-time employees in HK and incur at least HK$2 million in annual operating expenses in HK. |
Activities | Must not engage in general commercial or industrial trade (it must be a pure investment vehicle). |
4. Key Steps to Go Live
Open a Private Bank Account: This is often the longest part of the process. Having a clear family wealth source and "Know Your Customer" (KYC) documentation is vital.
Appoint an SFO: You must establish a separate Single Family Office entity (usually a private company) to manage the FIHV.
No License Needed (Usually): If the SFO only manages the assets of the family (and does not provide services to external third parties), it typically does not require a license from the Securities and Futures Commission (SFC).
Tax Election: Unlike other jurisdictions, you don't "apply" for the tax break upfront. You make an irrevocable election in writing when filing your first tax return.
Important Note on 2026 Regulations
Hong Kong has recently introduced the New Capital Investment Entrant Scheme (CIES). If you are looking to obtain residency while setting up your FIHV, you can combine the two by investing HK$30 million into permitted assets, which can potentially be held within your family office structure.
Checklist of the Documents You'll Need for the "Know Your Customer" (KYC) process with a Hong Kong Bank
"HK Family Office KYC Checklist" containing the documentation you'll need for the banking and registration process.
HK Family Office Bank KYC Checklist
1. Entity Documents
• Certificate of Incorporation & Business Registration Certificate (BRC)
• Articles of Association
• Ownership Structure Chart (certified by a CPA or Lawyer)
• Register of Directors, Members, and Secretaries
2. Family & Beneficial Owner Info
• Passports and Proof of Address for all Beneficial Owners (holding >25%)
• Passports and Proof of Address for all Directors and Authorized Signatories
• Proof of Relationship (Birth/Marriage certificates) for family members
3. Wealth & Fund Verification
• Source of Wealth (SoW): Detailed narrative of how the family wealth was generated (e.g., sale of business, inheritance, investments).
• Source of Funds (SoF): Bank statements showing the specific funds to be transferred to the new HK account.
• Supporting Evidence: Audit reports of family businesses, tax filings, or legal settlement documents.
4. Operational Documents
• Investment Policy Statement (IPS) or Business Plan for the FIHV.
• Proof of the Single Family Office (SFO) setup in Hong Kong.
How Bestar Hong Kong Can Help
How to Register a Family-owned Investment Holding Vehicle?
In 2026, Bestar Hong Kong serves as a specialized "one-stop-shop" for families looking to navigate the dual complexity of corporate registration and the stringent 0% tax concession requirements.
Here is how Bestar optimizes the setup of a Family-owned Investment Holding Vehicle (FIHV) using our local expertise.
1. Structural Design & Incorporation
Bestar ensures your structure is built to qualify for tax exemptions from day one, rather than trying to "fix" it later.
Dual-Entity Setup: They handle the simultaneous incorporation of the FIHV (to hold assets) and the SFO (to manage them), ensuring they meet the 95% beneficial ownership rule.
Articles of Association: Bestar drafts specialized Articles that include "Safe Harbor" provisions and share transfer restrictions required to protect your tax-exempt status under the Inland Revenue Ordinance.
Licensed Secretarial Services: As a licensed TCSP (Trust or Company Service Provider), Bestar fulfills the mandatory requirement for a local Company Secretary.
2. Tax & Substance Compliance
The HK tax department is strict about "substance." Bestar manages the high-stakes compliance details:
Substantial Activity Management: We track your local operating expenditure (minimum HK$2M) and staffing (minimum 2 qualified employees) to ensure you don't lose your 0% tax status.
Irrevocable Election Filing: We manage the formal written election process required to claim the tax concession during your annual filing.
Annual Audit: Bestar provides statutory audits that satisfy both the Companies Registry and the Inland Revenue Department (IRD).
3. Banking & "Know Your Customer" (KYC)
The biggest hurdle in Hong Kong for 2026 is bank account opening. Bestar bridges this gap by:
KYC Pre-Screening: Reviewing your Source of Wealth (SoW) and Source of Funds (SoF) documentation before submission to avoid bank rejections.
Direct Introductions: Leveraging their network with private banks (like HSBC, Standard Chartered, and BOC) to streamline the application for investment holding accounts.
4. Immigration & Residency (New CIES)
If your family is seeking residency through the New Capital Investment Entrant Scheme (CIES):
One-Stop Relocation: Bestar coordinates the HK$30 million investment verification with the Immigration Department.
Visa Management: We handle dependent visas for spouses and children, providing a seamless transition for the entire family.
Why Bestar for 2026?
Feature | Benefit |
Local TCSP License | Guaranteed legal compliance and AML/KYC oversight. |
SFC Guidance | Advising on "carve-outs" so your SFO avoids unnecessary licensing. |
Transparent Fees | Fixed packages (typically USD 2,000 – 3,500 for full setup). |
Cost breakdown for Bestar's specific "Family Office" package versus their standard company incorporation
In 2026, Bestar Hong Kong serves as a specialized partner for families looking to bridge the gap between simple incorporation and the complex "Substantial Activity" requirements of the 0% tax regime.
We focus on "Next-Gen Compliance," which integrates cloud-based accounting and AI-driven auditing to meet the 2026 standards of the Inland Revenue Department (IRD).
1. Bestar's 2026 Pricing Structure
Bestar offers tiered services depending on whether you are setting up a standard trading company or a high-value Family Investment Holding Vehicle (FIHV).
Standard Company vs. Family Office Setup
Cost Category | Standard HK Company | Family Office (FIHV + SFO) |
Setup Fee | ~HK$5,500 | ~HK$15,000 – $25,000+ |
Gov Fees (Inc. BRC) | HK$3,895 | HK$7,790 (Two entities: FIHV & SFO) |
Co. Secretary | HK$2,400 / yr | HK$5,000+ / yr (Higher compliance load) |
Registered Address | HK$2,100 / yr | HK$4,000+ (Premium CBD address) |
Banking Assist | HK$2,400 | Included in FO Package |
Compliance Audit | HK$5,000 – $10,000 | HK$25,000+ (Required for Tax Concession) |
Bestar Advantage: For Family Offices, Bestar bundles the FIHV and the SFO into a single project. This ensures the 95% ownership and management control links are legally water-tight for tax purposes.
2. Specialized Family Office Support
Bestar goes beyond the paperwork to handle the "Substance" requirements that the IRD audits in 2026:
Substantial Activity Management: We monitor your annual local expenditure (ensuring you hit the HK$2M floor) and provide HR support to help you employ the 2 mandatory qualified staff.
FSIE 2.0 Health Check: We ensure your holding vehicle complies with the latest Foreign-Sourced Income Exemption (FSIE) rules, protecting your offshore dividends from being taxed.
SFC Licensing Guidance: We provide a legal opinion on whether your SFO qualifies for the "Carve-out" (meaning you don't need a license) or if you need to apply for a Type 4 or 9 license.
Asset Under Management (AUM) Certification: To claim the 0% tax rate, you must prove HK$240M in assets. Bestar’s CPAs provide the necessary NAV (Net Asset Value)
certification required for your tax filing.
3. Bestar’s "One-Stop" Relocation (CIES)
For families utilizing the New Capital Investment Entrant Scheme (CIES), Bestar acts as the central coordinator:
Investment Verification: We coordinate with the Immigration Department for the HK$30M investment check.
Visa Processing: We handle the Entry Permits and subsequent "Top Talent" or "Entrepreneur" visa extensions for family members.
Ongoing Maintenance: We manage the annual "Asset Account" reporting required to maintain your residency status.
"Project Timeline" for Bestar to Set Up both your FIHV and SFO
In 2026, setting up a Family-owned Investment Holding Vehicle (FIHV) and a Single Family Office (SFO) with Bestar is a high-speed process for the legal entities, followed by a deeper compliance phase.
Using Bestar’s "Fast-Track" digital e-incorporation, the legal entities can exist in under 24 hours, but the full operational setup (including banking and tax readiness) typically spans 3 to 4 months.
Phase 1: Structural Setup (Weeks 1–2)
Bestar focuses on the legal foundation to ensure you qualify for the 0% tax rate.
Entity Formation: Simultaneous incorporation of the FIHV (Investment Vehicle) and SFO (Management Co).
Digital Filing: Using the 2026 e-Registry, Certificate of Incorporation and Business Registration Certificates are often issued within 14 hours.
Statutory Appointments: Bestar takes the role of the mandatory local Company Secretary and provides the CBD registered address.
Phase 2: Banking & Asset Onboarding (Weeks 3–12)
This is the most critical stage where Bestar’s "Bank Onboarding Kit" is utilized.
KYC Preparation: Bestar pre-audits your "Source of Wealth" narrative to meet strict 2026 AML standards.
Private Bank Introduction: Coordination with major HK banks (HSBC, StanChart, etc.) for the investment account.
Asset Transfer: Assisting in the legal documentation for moving the HK$240 million minimum asset base into the new FIHV.
Phase 3: Substance & Tax Election (Month 4 onwards)
Once the vehicle is funded, Bestar solidifies the tax-exempt status.
Employment Setup: Assisting in hiring the 2 mandatory qualified employees (or managing work visas if bringing family staff from abroad).
OpEx Monitoring: Setting up accounting systems to track the required HK$2M annual spend in Hong Kong.
Irrevocable Tax Election: Bestar’s tax partners file the formal election with the Inland Revenue Department (IRD).
Bestar Project Roadmap 2026
Milestone | Estimated Duration | Key Deliverable |
Project Kick-off | Day 1 | Structural Design & KYB Review |
Legal Incorporation | Day 2–3 | Certificates of Incorporation & BRC |
Bank Account Opening | Week 4–10 | Fully operational HKD/USD investment account |
Asset Injection | Week 10–12 | AUM Certification (HK$240M+) |
Substance Readiness | Month 4 | Staffing & OpEx tracking systems live |
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