Redomiciliation of Companies to Hong Kong
On May 23, a new law came into force allowing companies to redomicile to Hong Kong — now foreign legal entities can change their jurisdiction without liquidation and continue operating under Hong Kong law.
Why this matters:
- Hong Kong is a neutral jurisdiction with a favorable tax regime.
- It competes successfully with the UAE, Mauritius, and the Seychelles.
- There is a Double Taxation Agreement (DTA) with Russia based on a beneficial 5-0-3 model (5% or 10% withholding tax on dividends, 3% on royalties, 0% on interest).
Tax advantages:
- Application of the DTA with Russia.
- No withholding tax on dividends and interest.
- Possibility of foreign-sourced income being tax-exempt (if conditions are met).
- Suitable for holding, logistics, international trade, and IP structures.
Important considerations:
- Real economic substance is required — office, staff, and management in Hong Kong.
- Opening bank accounts can be challenging: banks often reject applications from companies with Russian beneficiaries.
- Risk of shifting tax residency to another jurisdiction if actual management is conducted outside Hong Kong.
If your business structure includes foreign companies registered in unfriendly jurisdictions, the legal experts at AT Law Firm are ready to assist with assessing the feasibility and providing full support for redomiciling to Hong Kong — from document preparation to obtaining the certificate and resolving related tax and corporate matters.
