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Does a Hong Kong company pay tax on profits earned overseas?

Generally no. Profits sourced outside Hong Kong are outside the profits tax charge, even if the company is incorporated here. The exceptions are certain foreign-sourced passive income received in Hong Kong by members of multinational groups under the FSIE regime, and any profits the IRD finds are actually sourced in Hong Kong.

Incorporation in Hong Kong does not decide tax. What matters is whether the profits arise in or are derived from Hong Kong.

Generally not taxable: profits from a business activity whose profit-producing operations take place outside Hong Kong, if you can support that position with evidence.

Still taxable or at risk:

  • Profits the IRD concludes are sourced in Hong Kong despite the claim (for example, contracts negotiated and concluded here).
  • Foreign-sourced dividends, interest, disposal gains and IP income received in Hong Kong by a member of a multinational enterprise group, unless an exception such as economic substance or the participation exemption is met (FSIE regime, from 1 January 2023 for most categories and 1 January 2024 for other disposal gains).
  • Royalties for the use of intellectual property in Hong Kong, which are deemed to be Hong Kong profits.

In your return: the profits tax return asks you to report amounts you exclude as offshore, so excluded profits are visible to the IRD. Keep the contracts, correspondence and records of who did what, and where.

A company with only individual shareholders and no foreign group is not within the FSIE definition of a multinational group member.

  • Inland Revenue Ordinance (Cap. 112), s.14
  • Inland Revenue Ordinance (Cap. 112), ss.15H–15M (FSIE)

Sources

Applies to YA 2025/26 · Last reviewed 29 October 2026

General information for business owners, not legal, tax or professional advice. Rules change, so check the sources or ask a licensed professional before you act.

    Does a Hong Kong company pay tax on profits earned overseas? | OCTIS