Defined terms with their Hong Kong statutory anchor
Definitions for Hong Kong control architecture.
FIHV, LPF, SFO, AMLO, TCSP, PTC, section 14D, section 41X, Part 17A, two-tiered profits tax, patent box, and the Hong Kong ordinances they belong to.
- AMLO
- Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). Sets out customer due diligence, beneficial-owner and control disclosure at applicable thresholds, record-keeping, and TCSP licensing obligations for Hong Kong authorised institutions and trust or company service providers. See e-Legislation Cap. 615.
- Banking Ordinance (Cap. 155)
- The principal statute governing authorised institutions in Hong Kong, administered by the Hong Kong Monetary Authority. See e-Legislation Cap. 155.
- Cap. 29 (Trustee Ordinance)
- The Trustee Ordinance, as amended in 2013. The 2013 amendments abolished the rule against perpetuities for Hong Kong trusts and codified reserved settlor powers in section 41X. See e-Legislation Cap. 29.
- Cap. 76 (Recognition of Trusts Ordinance)
- Gives effect in Hong Kong to the Hague Convention on the Law Applicable to Trusts and on their Recognition. See e-Legislation Cap. 76.
- Cap. 112 (Inland Revenue Ordinance)
- The Hong Kong tax statute governing profits tax, salaries tax, and property tax, and the FIHV, corporate treasury centre, and patent box concessionary regimes. See e-Legislation Cap. 112.
- Cap. 117 (Stamp Duty Ordinance)
- Governs stamp duty on Hong Kong property transfers, share transfers, and certain leases. See e-Legislation Cap. 117.
- Cap. 622 (Companies Ordinance)
- The principal statute governing Hong Kong companies. Part 17A, in force since 23 May 2025, governs inward re-domiciliation of foreign-incorporated companies. See e-Legislation Cap. 622.
- Cap. 637 (LPF Ordinance)
- Limited Partnership Fund Ordinance, in force since 31 August 2020. Provides the registration regime for Hong Kong limited partnership funds. See e-Legislation Cap. 637.
- Companies Registry
- The Hong Kong public body responsible for company incorporation, registration of charges, TCSP licensing, and the re-domiciliation regime under Part 17A of the Companies Ordinance (Cap. 622). See cr.gov.hk.
- Corporate Treasury Centre (CTC)
- A Hong Kong entity that elects under section 14D of the Inland Revenue Ordinance (Cap. 112) for the corporate treasury centre concessionary profits tax rate of 8.25 percent on qualifying profits, half of the standard 16.5 percent rate, subject to substantial-activity tests on qualified employees and operating expenditure. See AGATE corporate treasury centre page.
- FIHV
- Family-owned Investment Holding Vehicle. A vehicle eligible under the Hong Kong family-office tax regime for 0 percent profits tax on qualifying transactions, subject to minimum net-asset-value, operating expenditure, and qualified-employees thresholds. 2026-27 Budget asset-management tax-concession proposals should be checked against enacted amendment legislation and IRD guidance before being relied on. See IRD FIHV page and AGATE family-office insight.
- HKMA
- Hong Kong Monetary Authority. The central banking institution responsible for monetary stability, banking supervision under the Banking Ordinance (Cap. 155), and oversight of authorised institutions and stored-value facility licensees. See hkma.gov.hk.
- IRD
- Inland Revenue Department. The Hong Kong tax authority administering the Inland Revenue Ordinance (Cap. 112), the FIHV concession, the patent box regime, the corporate treasury centre concession, and the re-domiciliation tax-transition provisions. See ird.gov.hk.
- LPF
- Limited Partnership Fund. A private fund vehicle registered under the Limited Partnership Fund Ordinance (Cap. 637), in force since 31 August 2020. Suits closed-ended private funds with a general partner, an investment manager, and a fund administration record. See AGATE LPF page.
- MLRO
- Money Laundering Reporting Officer. The designated officer of a Hong Kong authorised institution or TCSP responsible for receiving and acting on suspicious transaction reports under the AMLO (Cap. 615).
- OFC
- Open-ended Fund Company. A Hong Kong open-ended collective investment scheme structure registered under Part IVA of the Securities and Futures Ordinance (Cap. 571).
- Patent Box Regime
- The Hong Kong concessionary profits tax rate of 5 percent on qualifying intellectual property income, against the standard 16.5 percent rate, under the Inland Revenue (Amendment) (Tax Concessions for Intellectual Property Income) Ordinance 2024, gazetted on 5 July 2024. Uses the OECD nexus approach. Local registration requirement applies from 5 July 2026. See IRD patent box page and AGATE IP holding page.
- Part 17A
- The inward company re-domiciliation regime added to the Companies Ordinance (Cap. 622) and brought into force on 23 May 2025. Allows eligible foreign-incorporated companies to transfer their legal seat to Hong Kong without winding up. See AGATE re-domiciliation page.
- PTC
- Private Trust Company. A company established to act as trustee for a specific family's trusts. Hong Kong does not operate a standalone PTC statute comparable to Cayman, BVI, or Jersey; a Hong Kong PTC sits inside the general trust-business framework and the TCSP licensing regime under the AMLO (Cap. 615). See AGATE Hong Kong PTC page.
- Re-domiciliation
- The transfer of a company's legal seat from one jurisdiction to another without winding up or losing legal identity. Hong Kong's inward re-domiciliation regime came into force on 23 May 2025 under Part 17A of the Companies Ordinance (Cap. 622).
- Reserved Settlor Powers
- Powers retained by the settlor under a Hong Kong trust deed, expressly permitted under section 41X of the Trustee Ordinance (Cap. 29) as amended in 2013, without invalidating the trust. The boundary with sham-trust risk depends on the drafting and the facts.
- Section 14D
- The Inland Revenue Ordinance (Cap. 112) provision under which a qualifying corporate treasury centre may elect for the concessionary profits tax rate of 8.25 percent on qualifying profits.
- Section 41X
- The Trustee Ordinance (Cap. 29) provision codifying reserved settlor powers under Hong Kong trust law, introduced by the Trust Law (Amendment) Ordinance 2013.
- SFC
- Securities and Futures Commission. The Hong Kong regulator for securities, futures, and asset-management activities under the Securities and Futures Ordinance (Cap. 571). See sfc.hk.
- SFO (statute)
- Securities and Futures Ordinance (Cap. 571). The principal statute governing Hong Kong's securities and futures markets, fund managers, intermediaries, and corporate finance activities.
- SFO (single family office)
- Single Family Office. A management entity established to serve a single family's wealth, investment, and governance functions. Under the Hong Kong FIHV regime, an eligible SFO managing a qualifying FIHV is required to maintain a minimum operating presence in Hong Kong.
- SPV
- Special Purpose Vehicle. A company established for a specific deal, investment, or asset-holding purpose, typically with limited liability and a defined operating scope. See AGATE private deal SPV page.
- Stamp Duty Ordinance
- See Cap. 117 above.
- TCSP
- Trust or Company Service Provider. A licence under the AMLO (Cap. 615) required to carry on a trust or company service business in Hong Kong, administered through the Companies Registry's TCSP licensing portal. The regime came into operation on 1 March 2018; licences are generally valid for three years. See tcsp.cr.gov.hk.
- Trustee Ordinance
- See Cap. 29 above.
- Two-tiered Profits Tax
- The Hong Kong profits tax regime applying a concessionary lower-tier rate on the first prescribed band of assessable profits and the standard rate above that, under the Inland Revenue Ordinance (Cap. 112).
Private review
Definitions matter when the structure is live.
Use the private enquiry path only when Hong Kong will handle real ownership, capital, real estate exposure, IP, treasury, management, or governance pressure under documented review.