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Hong Kong Company Registrations Hit Record 1.6 Million as Tax Treaty Network Expands to 59

ong Kong's appeal as a global business hub continues to strengthen, with the Companies Registry reporting on July 17 that the total number of local companies and re-domiciled companies registered under the Companies Ordinance reached an all-time high of 1,609,720 as at end-June 2026. A total of 122,481 new local and re-domiciled companies were registered during the first half of the year.

The surge in registrations was accompanied by record numbers of non-Hong Kong companies establishing a presence in the city. Some 903 non-Hong Kong companies newly set up places of business in Hong Kong during H1 2026, bringing the total number of registered non-Hong Kong companies to 16,014 -- also a historic high.

The Company Re-domiciliation Regime, which took effect on May 23, 2025, has seen strong uptake in its first full year. By end-June 2026, the Companies Registry had received 70 re-domiciliation applications, with 42 companies successfully re-domiciled to Hong Kong, including two insurers and one listed company. These companies originated from jurisdictions including the British Virgin Islands, Luxembourg, the Cayman Islands, and Bermuda.

The fund sector also showed robust growth. Limited partnership fund (LPF) registrations rose by 406 in H1 2026, bringing the total to 1,729. Open-ended fund company (OFC) incorporations increased by 79, reaching 752 in total. Meanwhile, 333 new licences were granted for trust or company service providers, pushing the total number of licensees to 7,412.

Baptist University associate professor Billy Mak attributed the record figures to Hong Kong's economic recovery -- GDP grew 5.9% in Q1 2026 -- and the government's "headquarters economy" initiative. He also noted that the OECD's BEPS 2.0 global minimum tax rules have reduced the appeal of traditional tax havens, prompting more firms to establish genuine operations in Hong Kong.

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Tax Treaty Milestone with Nigeria

On July 13, Hong Kong signed a comprehensive avoidance of double taxation agreement (CDTA) with Nigeria, marking the 59th such agreement in Hong Kong's network and the fourth concluded this year. The pact was signed by Secretary for Financial Services and the Treasury Christopher Hui and Nigerian Finance Minister Taiwo Oyedele.

Under the CDTA, Nigeria's withholding tax rates on dividends and interest for Hong Kong residents will be reduced from the current 10% to 7.5%. Hong Kong companies receiving royalties from Nigeria will enjoy the same reduced rate. The agreement also provides tax credit mechanisms preventing double taxation on cross-border income.

"Nigeria is the most populous country in Africa and an important trading partner of Hong Kong," Mr Hui said. "The continued expansion of our CDTA network provides Hong Kong-based enterprises with greater tax certainty when expanding overseas."

The agreement will take effect after both sides complete ratification procedures. In Hong Kong, the Chief Executive in Council will make an order under the Inland Revenue Ordinance, subject to Legislative Council negative vetting.

Looking Ahead

For businesses and investors, the record registration numbers underscore Hong Kong's enduring competitiveness despite global headwinds. The expanding tax treaty network -- now covering 59 jurisdictions -- further enhances the city's position as a preferred jurisdiction for cross-border investment and corporate treasury operations.

Companies considering Hong Kong incorporation should note that the two-tier profits tax regime (8.25% on first HK$2 million, 16.5% thereafter) remains in place, and mandatory electronic filing of profits tax returns through the Business Tax Portal is now in effect. As the business environment evolves, staying informed on registration requirements and treaty benefits will be essential for compliance and tax optimisation.

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Sources: Companies Registry Press Release (July 17, 2026); IRD Press Release (July 13, 2026); Hong Kong SAR Government Information Services Department.