Hong Kong registration plan may lure global insurers

Its redomiciliation scheme could attract as many as 300 firms in two years.

A regime that lets companies shift their legal base to Hong Kong without winding up could encourage more insurers and multinationals to register in the city, legal and tax experts said.

“There has been market interest and demand, particularly from the insurance sector, for redomiciliation into Hong Kong,” Simmons & Simmons LLP Partner Claudia Yiu told Hong Kong Business.

She said the program is expected to boost demand for audit, accounting, and legal services. “Additionally, it is anticipated that redomiciled companies will bring increased investment and job opportunities, as many are likely to relocate parts of their business operations to Hong Kong,” she said in an emailed reply to questions.

Two global insurers have announced plans to move from Bermuda after the scheme was introduced in May, said Yvette Chan, managing director for tax at Alvarez & Marsal Hong Kong. 

AXA Hong Kong and Macau will transfer AXA China Region Insurance Company (Bermuda) Ltd., while Manulife (International) Ltd. is expected to complete its transfer in November.

As of 2 September, 95 of the 159 authorised insurers in Hong Kong were locally incorporated, according to the Insurance Authority.

Chan said the regime could attract 50 to 100 companies in its first year, and as many as 300 within two years, depending on promotion and market conditions.

She noted that more than 15,000 companies are operating in the city but incorporated elsewhere. As of 11 July, the Companies Registry had logged 265 enquiries about the scheme, while its dedicated webpage recorded more than 22,000 visits and 42,000 downloads.

Firms applying to shift their registration must be financially sound and could pay debts which fall due within the period of 12 months from the application date, according to Grace Tso, a partner at Baker McKenzie. They must also comply with the rules of their original jurisdiction.

Once the requirements are observed, the company can apply to the Companies Registry for re-domiciliation by filing a form together with supporting documents, Tso said in an email. The re-domiciliation takes effect when the Companies Registry issues a certificate confirming the re-domicile. The company must then cancel its original registration.

The Companies Registry may refuse an application if a firm is deemed likely to be used unlawfully or against the public interest. Processing time is about two weeks for complete submissions, Tso said.

Yiu said the registry charges filing fee of $6,050 for online submissions and $6,725 for paper filings. Extra costs cover legal opinions, director certifications, accounting documents, and advisory support. Legal opinions must be issued within 35 days before application.

Once approved, companies receive both a certificate of re-domiciliation and a business registration certificate, and must complete cancellation in their former jurisdiction within 120 days.

Jeckle Chiu, a partner at Johnson Stokes & Master, said companies making the shift will fall under Hong Kong’s profit tax regime. “The government will provide unilateral tax credits to mitigate any resulting double taxation,” he added.

He said companies incorporated in Hong Kong gain market access to Mainland China under the Closer Economic Partnership Arrangement (CEPA), whilst benefiting from simplified rules under the updated Companies Ordinance.

He said the framework strengthens Hong Kong’s role as China’s preferred offshore hub. “It is a true manifestation of ‘One Country, Two Systems’ that will ultimately benefit the city,” he added.

Chan said the scheme improves Hong Kong’s competitiveness against hubs like Singapore, noting that it does not impose economic substance requirements. This allows firms to shift registration without setting up large offices or meeting staffing thresholds.

Tso added that rising compliance costs and global tax rules have made traditional offshore centres such as Bermuda less appealing.

“Hong Kong has been a strong contestant as a business hub for companies seeking to do business in Mainland China and Asia,” she said. “It makes more sense for foreign companies with substantive operations in Hong Kong, Mainland China, or Asia-Pacific to take advantage of the new regime and change their actual place of domicile to Hong Kong.”