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Profits Tax

Key highlights

hands
No changes proposed to tax rates Reduction of 100% in Profits Tax payable for 2020-21, subject to a ceiling of HKD 10,000
To review relevant tax arrangements in relation to family office
													
													To provide tax concessions for carried interest issued by private equity funds operating in Hong Kong.
To provide a 50% tax concession to eligible insurance businesses (including marine insurance and specialty insurance)
Key highlights
  • No changes proposed to tax rates Reduction of 100% in Profits Tax payable for 2020-21, subject to a ceiling of HKD 10,000
  • To review relevant tax arrangements in relation to family office

    To provide tax concessions for carried interest issued by private equity funds operating in Hong Kong.
  • To provide a 50% tax concession to eligible insurance businesses (including marine insurance and specialty insurance)
Tax rates
Corporations Unincorporated businesses
Standard tax rate* 16.5% 15%
Two-tiered Profits Tax regime
Qualifying taxpayers may be taxed at the following reduced rates:
  • First HKD 2 million of assessable profits
  • Remaining balance
Note: Only one entity within a group can benefit from the above reduced rates.


  • 8.25%
  • 16.5%


  • 7.5%
  • 15%

*Concessionary regimes are available for certain specified industries or business activities.

Profits Tax on royalties paid to non-residents

When royalty payment is made to a non-resident associated person and the underlying intellectual property has once been owned by any Hong Kong taxpayer, the assessable profits of the non-resident associated person are deemed to be 100% of the payment (i.e. effective tax rate is 16.5%). In other cases, the assessable profits of the non-resident person are generally deemed to be 30% of the payment (i.e. effective tax rate is 4.95%). The effective tax rate may be reduced under the terms of the applicable double taxation agreement or election of the two-tiered Profits Tax rate.

No changes proposed in tax rates for 2021-22

Capital allowances
Depreciation allowances for plant and machinery
  • Initial allowance
  • Annual allowance

  • 60%
  • 10%, 20% or 30%
Industrial building allowances
  • Initial allowance
  • Annual allowance

  • 20%
  • 4%
Commercial building allowance 4%
Building refurbishment 20% deduction for 5 years
Expenditure on computer hardware and software 100% deduction
Expenditure on environmentally friendly machinery and equipment 100% deduction
Enhanced tax deduction for qualifying research and development expenditure 300% (for the first HKD 2 million)
200% (for the remaining balance)

Source: Inland Revenue Ordinance

Salaries Tax

Key highlights

No changes proposed to tax rates and allowances for individuals

Reduction of 100% in Salaries Tax payable for 2020-21, subject to a ceiling of HKD 10,000

Key highlights
  • No changes proposed to tax rates and allowances for individuals
  • Reduction of 100% in Salaries Tax payable for 2020-21, subject to a ceiling of HKD 10,000
Tax rates

The tax charge for Salaries Tax is the lower of the:

  1. Net assessable income less charitable donations and allowable deductions at the standard rate (15%); or
  2. Net assessable income less charitable donations, allowable deductions and personal allowances, charged at the progressive rates below.
2014-15 to 2016-17
Rate HKD
2017-2018
Rate HKD
2018-19 to 2021-22
Rate HKD
First HKD 40,000 2% 800 First HKD 45,000 2% 900 First HKD 50,000 2% 1,000
Next HKD 40,000 7% 2,800 Next HKD 45,000 7% 3,150 Next HKD 50,000 6% 3,000
Next HKD 40,000 12% 4,800 Next HKD 45,000 12% 5,400 Next HKD 50,000 10% 5,000
Next HKD 50,000 14% 7,000
Remaining balance 17% 17% 17%
Allowances for individuals
2015-2016
HKD
2016-2017
HKD
2017-2018
HKD
2018-2019
HKD
2019-2020
HKD
2020-2021
HKD
2021-2022
HKD
Personal allowances Basic 120,000 132,000 132,000 132,000 132,000 132,000 132,000
Married 240,000 264,000 264,000 264,000 264,000 264,000 264,000
Single parent 120,000 132,000 132,000 132,000 132,000 132,000 132,000
Disabled - - - 75,000 75,000 75,000 75,000
Child allowances 1st to 9th child (each)
Year of birth 200,000 200,000 200,000 240,000 240,000 240,000 240,000
Other years 100,000 100,000 100,000 120,000 120,000 120,000 120,000
Dependent parent and grandparent allowances Aged 60 or above 40,000 46,000 46,000 50,000 50,000 50,000 50,000
Aged between 55 and 59 20,000 23,000 23,000 25,000 25,000 25,000 25,000
Additional dependent parent and grandparent allowances Aged 60 or above 40,000 46,000 46,000 50,000 50,000 50,000 50,000
Aged between 55 and 59 20,000 23,000 23,000 25,000 25,000 25,000 25,000
Disabled dependent (spouse/child/parent/ grandparent/brother/sister) allowances 66,000 66,000 75,000 75,000 75,000 75,000 75,000
Dependent brother/sister allowances 33,000 33,000 37,500 37,500 37,500 37,500 37,500
Deductions – maximum limit
2015-2016
HKD
2016-2017
HKD
2017-2018
HKD
2018-2019
HKD
2019-2020
HKD
2020-2021
HKD
2021-2022
HKD
Self-education expenses 80,000 80,000 100,000 100,000 100,000 100,000 100,000
Elderly residential care expenses 80,000 92,000 92,000 100,000 100,000 100,000 100,000
Mandatory contributions to recognised retirement schemes 18,000 18,000 18,000 18,000 18,000 18,000 18,000
Home loan interest 100,000
Approved charitable donations 35% of assessable income
Qualifying voluntary health insurance scheme policy premiums - - - - 8,000 per insured person 8,000 per insured person 8,000 per insured person
Annuity premiums and MPF voluntary contributions - - - - 60,000 60,000 60,000

Source: Inland Revenue Ordinance

Property Tax, Rates and Stamp Duty

Key highlights

Stamp Duty

Raise the rate of Stamp Duty on stock transfers from 0.1% to 0.13% (aggregate 0.26%)

Property Tax

No changes proposed

Rates (domestic property)

Rates waiver for each domestic property for all 4 quarters of 2021-22, subject to a ceiling of HKD 1,500 per quarter in the first 2 quarters and HKD 1,000 per quarter in remaining 2 quarter

Rates (non-domestic property)

Rates waiver for each non-domestic property for all 4 quarters of 2021-22, subject to a ceiling of HKD 5,000 per quarter in the first 2 quarters and HKD 2,000 per quarter in the remaining 2 quarters

Key highlights
Stamp Duty

Raise the rate of Stamp Duty on stock transfers from 0.1% to 0.13% (aggregate0.26%)

Property Tax

No changes proposed

Rates (domestic property)

Rates waiver for each domestic property for all 4 quarters of 2021-22, subject to a ceiling of HKD 1,500 per quarter in the first 2 quarters and HKD 1,000 per quarter in remaining 2 quarter

Rates non-domestic property)

Rates waiver for each non-domestic property for all 4 quarters of 2021-22, subject to a ceiling of HKD 5,000 per quarter in the first 2 quarters and HKD 2,000 per quarter in the remaining 2 quarters

Stamp Duty

Lease of immovable properties
Lease term Rate
Not defined or is uncertain 0.25% of the yearly or average yearly rent
Does not exceed 1 year 0.25% of the total rent payable over the term of the lease
Exceeds 1 year but not exceeding 3 years 0.5% of the yearly or average yearly rent
Exceeds 3 years 1% of the yearly or average yearly rent
Sale and purchase of Hong Kong stock

0.26% of the consideration or the market value of the stock as at the transfer date – whichever is higher

Sale on transfer of immoveable properties
Ad valorem stamp duty
Property consideration
Exceeds Does not exceed Flat rate
(for residential properties)
Scale 2 rates*#
(for non-residential properties)
Scale 2 rates*
(for Hong Kong permanent residents who do not own other residential properties and in other specified circumstances)
HKD 2,000,000 15% HKD 100 HKD 100
HKD 2,000,000 HKD 3,000,000 1.5% 1.5%
HKD 3,000,000 HKD 4,000,000 2.25% 2.25%
HKD 4,000,000 HKD 6,000,000 3.0% 3.0%
HKD 5,000,000 HKD 20,000,000 3.75% 3.75%
HKD 20,000,000 4.25% 4.25%

* Subject to marginal relief

# Applicable to any instrument executed on or after 26 November 2020 for the sale and purchase or transfer of non-residential property (subject to the enactment of the relevant amendment bill by the Legislative Council)

Special stamp duty on disposal of residential properties
Property holding period
Tax rate
6 months or less 20%#
More than 6 months but not exceeding 12 months 15%#
More than 12 months but not exceeding 36 months 10%#
Buyer’s stamp duty on acquisition of residential properties
Tax rate
For non-Hong Kong permanent residents 15%#

# On the sales consideration or market value of property at the date of sale (whichever is higher)

Property Tax

Tax rate 15%

The tax rate is applied to the “net assessable value” of the property which is calculated at the total rent receivable (net of rates) less 20% statutory allowance for repairs and outgoings.

Rates

Tax rate 5%

The tax rate is applied to the “rateable value” which is the estimated annual rental value of the property at a designated valuation reference date. As there has been no major change since 1995, the Government will review the rating system for any improvement.

Sources: Inland Revenue Ordinance, Stamp Duty Ordinance, Rating and Valuation Department’s website

© 2021 KPMG Tax Services Limited, a Hong Kong limited liability company and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

© 2021 KPMG, a Hong Kong partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.