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Hong Kong publishes draft legislation for inward company re-domiciliation

17 January 2025

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Global

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Hong Kong

A draft bill has been published that would implement an inward company re-domiciliation regime in Hong Kong.A re-domiciled company will be regarded as a Hong Kong-incorporated company, hence facilitating access to tax treaties and application of the proposed Pillar Two rules.The re-domiciliation itself should not trigger Hong Kong profits tax or stamp duty. Unilateral tax credits will be available to mitigate double taxation.  On 20 December 2024, Hong Kong published the draft bill1 to introduce a company re-domiciliation regime that enables non-Hong Kong-incorporated companies to re-domicile to Hong Kong. The regime will become effective upon the enactment of the bill.Under...