HONG KONG SAR, CHINA Trends and Developments Contributed by: Hui Wang and Hui Zheng, King & Wood
sively. The tax transparency of those arrangements must therefore be capable of being substantiated. Although the first CARF exchange of information is scheduled for 2028, reportable transaction data will begin to accumulate from 2027. Records concerning historical source of funds, platform transaction his - tories, cross-border transfer pathways and offshore holding arrangements may be difficult to reconstruct retrospectively. Family offices and relevant asset holders should use the transition period between leg - islative enactment and the commencement of sub - stantive reporting to review their tax and structural arrangements and improve their compliance position. Taken as a whole, the development of CARF and the amended CRS is consistent with Hong Kong’s ear - lier reforms to its foreign-sourced income exemption regime and its successful removal from the EU list of non-cooperative jurisdictions for tax purposes. These developments collectively reinforce Hong Kong’s position as a compliant and transparent international wealth management centre. Conclusion Hong Kong’s family wealth management policy in 2026 reflects a coherent underlying logic: • using enhanced SFO tax concessions to attract capital; • deepening the New CIES as an institutional chan - nel for capital and talent inflows; and • establishing international credibility through the implementation of CARF and the amended CRS.
Together, these developments support Hong Kong’s long-term positioning as a compliant wealth manage - ment hub, rather than a jurisdiction competing only on low tax rates. That positioning is attractive to high net worth families seeking a stable and transparent long-term platform. However, policy advantages come with compliance obligations: • the expanded SFO tax concessions require precise structural alignment; • the New CIES applications involve multi-layered pre-application planning; and • the CARF and the amended CRS require digital asset holding structures to be reviewed in advance. As the relevant bills progress through the legislative process, further implementation details will become clearer. Hong Kong’s legal framework for family wealth management is becoming more comprehensive. For families seeking to establish a long-term presence in Hong Kong, this is an appropriate time to review their structural arrangements and take advantage of the available policy window.
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