Family office legal &
structuring counsel in Hong Kong
Family office legal & structuring counsel in Hong Kong
TITUS is the legal backbone for family offices — setup, structuring, the Hong Kong tax concession, trusts and succession — bridging legacy wealth and frontier assets.
A Hong Kong law firm builds the legal and structuring foundation of a family office: it designs the holding and fund vehicles, establishes the trusts and succession plans that carry wealth to the next generation, and positions a qualifying Family-owned Investment Holding Vehicle (FIHV) for Hong Kong’s family office tax concession. At TITUS, we act as legal and structuring counsel — not day-to-day administrator or asset manager — advising on entity formation, governance and family constitutions, cross-border estate planning, regulatory and licensing questions, and the custody and structuring of both traditional and digital assets. The result is a structure designed to keep the operating business, the family’s private wealth, and the investment vehicle cleanly separated and tax-efficient, and to be built to last.
What is a family office, and why Hong Kong?
A family office is the structure a family uses to hold, govern and pass on significant wealth — investments, property and business interests — as a coordinated whole rather than through personal or operating-company accounts. It separates the management and decision-making layer (the family office itself) from the holding layer (the vehicles that own the assets), so wealth can be preserved, deployed and transferred deliberately.
Single-family office (SFO) vs multi-family office (MFO). A single-family office serves one family exclusively and, where it meets the qualifying conditions, may access Hong Kong’s tax concession. A multi-family office serves several families and is generally a licensed service provider. Which fits depends on your scale, your appetite for control and confidentiality, and whether you would rather own the infrastructure or share it.
Why Hong Kong. Hong Kong offers a rare combination for Asian and international families: a common-law legal system with genuine certainty, a gateway position into Greater China and the wider region, no capital gains tax and no estate duty, a growing double-taxation treaty network, and a dedicated family office tax concession introduced to attract exactly this capital. For families whose wealth increasingly spans both traditional assets and digital assets, Hong Kong’s parallel build-out of a virtual-asset regulatory regime — including the dual licensing framework for virtual asset trading platforms under the Securities and Futures Ordinance and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance — makes it uniquely suited to the next generation of wealth.
Where the lawyer fits. We are the legal and structuring counsel: we design the structure, secure its tax and regulatory footing, provide ongoing legal advice, and coordinate with your administrators, bankers, accountants, and investment managers rather than replacing them.
Our family office services
Family office setup & structuring
We design and implement the full legal architecture — selecting and forming the right entities (private companies, holding vehicles, OFCs, LPFs and SPVs), layering them for asset segregation and jurisdictional efficiency, and drafting the constitutional and operating documents that tie them together. Where the tax concession is in view, we design the Family-owned Investment Holding Vehicle and the single-family office to meet the qualifying conditions from the outset, recognising that those conditions are subject to legislative change. See Corporate & Commercial.
The Hong Kong family office tax concession (FIHV)
Hong Kong offers a profits-tax concession — a 0% rate on qualifying transactions and certain incidental transactions (capped at 5% of qualifying receipts) — for an eligible Family-owned Investment Holding Vehicle (FIHV) managed by an eligible single-family office, subject to conditions on family ownership, minimum assets and local substance. We assess whether your structure qualifies, design it to meet the criteria, and, where useful and appropriate, seek an advance ruling from the Inland Revenue Department on your specific facts; a ruling addresses the facts as presented and does not itself guarantee a particular tax outcome.
The FIHV regime is enacted under the Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance 2023, effective retrospectively from year of assessment 2022/23. In outline, the current qualifying conditions are:
- at least 95% of the beneficial interest in the FIHV held, directly or indirectly, by members of a single family (or wholly by charitable purposes or trusts settled by the family);
- the FIHV managed by an eligible single-family office (ESF office) that satisfies a 75% safe-harbour rule — at least 75% of the ESF office’s assessable profits must derive from services provided to specified persons of the family;
- an aggregate net asset value of Schedule 16C “specified assets” managed by the ESF office for the FIHV (or multiple FIHVs of the same family) of at least HK$240 million;
- a substance test requiring at least two qualified full-time employees in Hong Kong and at least HK$2 million of Hong Kong operating expenditure; and
- an irrevocable election, with a cap of 50 FIHVs per ESF office eligible for aggregation into the asset-value computation.
Qualifying transactions cover securities, private company shares, debentures and loan stock, futures and foreign exchange contracts, specified deposits, exchange-traded commodities, foreign currencies and OTC derivatives, as set out in Schedule 16C. Legislation is currently before the Legislative Council that, if passed, would broaden the minimum-asset test and expand the range of qualifying asset classes, with retrospective effect. It has not been enacted, and the position above reflects the regime as currently in force.
Trusts, succession & estate planning
We build the instruments that move wealth safely across generations and borders: Hong Kong-law and offshore trusts (Hong Kong permits settlor-reserved powers and dynastic trusts — the Perpetuities and Accumulations Ordinance was amended in 2013 to abolish the rule against perpetuities and the rule against excessive accumulations for Hong Kong trusts created on or after 1 December 2013, allowing trusts of unlimited duration — with statutory protection under the Trustee Ordinance (Cap. 29) for lifetime transfers of assets into a Hong Kong-law trust, which can help insulate the trust from certain foreign forced-heirship claims, subject to the specific facts and the approach of any foreign court asked to recognise or enforce such claims), wills and multi-jurisdiction will coordination, enduring powers of attorney, and probate and estate administration. Hong Kong abolished estate duty with effect from 11 February 2006, which — combined with these tools — makes it a strong base for planning an orderly, private succession. See our Wills & Estate Planning practice.
Fund & holding structures (OFC and LPF)
Many families run their investment layer through a Hong Kong fund vehicle. The Open-ended Fund Company (OFC) suits a pooled, open-ended, redeemable strategy in a regulated corporate wrapper; the Limited Partnership Fund (LPF) suits closed-end private-market strategies — private equity, venture and private credit — and co-investment alongside external managers. An FIHV may also establish family-owned special purpose entities (FSPEs) to hold specific investments, subject to conditions including that the FSPE holds no more than 50% of its assets in short-term assets. We advise on which vehicle fits, form it, and integrate it with the family’s holding and tax structure. See Investment Funds.
Governance & the family constitution
Structure without governance rarely survives a generation. We draft the family constitution or charter — the shared rules on decision-making, leadership, entry and employment, distributions and dispute resolution — and, crucially, align it with the binding legal documents (trust deeds, shareholders’ agreements, company constitutions) so that intentions are enforceable where it matters. We also establish philanthropy vehicles, including tax-exempt charitable structures recognised under section 88 of the Inland Revenue Ordinance.
Digital-asset & virtual-asset wealth
A growing share of family wealth is now held in tokens, not just shares and property. We structure how digital assets are held and transferred within the family office — addressing custody and private-key control, legal title, succession (who can access the assets if something happens to the holder), and whether any given activity engages Hong Kong’s virtual-asset regime, a determination that depends on the specific token, activity and counterparties involved. Hong Kong operates a dual licensing regime: centralised platforms trading security tokens require a licence for Type 1 (dealing in securities) and Type 7 (automated trading services) regulated activities under the Securities and Futures Ordinance, while platforms trading non-security tokens require a virtual asset service provider (VASP) licence under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance; operating without the required licence carries criminal penalties. This is where TITUS is genuinely differentiated: we combine traditional structuring with hands-on virtual-asset and stablecoin experience. See Cryptocurrency.
Regulatory, licensing & compliance
We map your activities against Hong Kong’s regulatory perimeter. Whether a single-family office requires a licence under the Securities and Futures Ordinance depends on whether its activities amount to a regulated activity carried on as a business in Hong Kong; a single-family office that does not carry on business for profit and serves only its own family will generally fall outside the licensing requirement, but this must be assessed against the office’s specific activities, and multi-family offices providing services to third-party families are generally required to be licensed. We also handle AML/KYC obligations under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, Common Reporting Standard (CRS) reporting, the substance requirements underpinning the FIHV concession, and data privacy compliance under the Personal Data (Privacy) Ordinance. See Regulatory.
Disputes, asset protection & confidentiality
Good structuring prevents most disputes by making roles, rights, distributions and succession explicit before problems arise. Where conflict does occur — trust disputes, shareholder or partnership disputes, contentious probate, intra-family disputes — the right structure makes resolution faster, more discreet and more contained, whether through negotiation, mediation, arbitration or the courts. See Family for family and matrimonial matters.
Who we help
Old-money, multi-generational families
Established families focused on preserving and transferring wealth: keeping the operating business and the family’s private capital cleanly separated, planning succession before it becomes contentious, building governance that survives the founder, and doing all of it with discretion and tax efficiency.
New-wealth founders — tech, crypto and the new economy
First-generation wealth after a liquidity event, a token raise or a company sale. You need a firm that can move at the speed of a liquidity event, that understands digital-asset wealth as fluently as equity, and that can put a holding and succession structure in place before the capital is deployed or distributed.
Family office operators, MFOs and professional advisors
Multi-family offices, single-family office executives and advisors who need Hong Kong legal counsel for their principals — structuring, licensing and regulatory analysis, fund vehicles, and ongoing counsel — delivered as a discreet, reliable back office to your team.
Why TITUS
Legacy meets frontier. Few Hong Kong firms can move from a succession plan to a stablecoin licence in the same conversation. TITUS pairs traditional wealth and succession structuring with genuine, hands-on virtual-asset credibility — the combination families now need as wealth spans trusts and tokens.
Hong Kong as your hub. We are on the ground in Hong Kong, in common law, and built for cross-border work across Greater China and Asia.
Commercial, discreet, responsive. Michael Titus read finance before law; the firm reads a term sheet the way a principal does. We keep pace with liquidity events, protect confidentiality, and focus on getting the structure right once, so it lasts.
How we work
- Scope & structure design. We understand the family, the assets and the goals, then design the structure — entities, trusts, tax positioning and governance.
- Implementation & coordination. We form the vehicles and draft the documents, engage the IRD where useful, and coordinate with your tax, banking, administration and investment providers.
- Ongoing legal counsel. We stay on as the family’s legal and structuring counsel — for new investments, regulatory change, succession events and disputes.
Arrange a confidential consultation with our Family Office team.
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What can fund formation lawyers help with?
Asset management legal services and investment fund lawyers are integral in the structuring and restructuring of different funds. They can help by preparing partnership agreements, drafting contracts, and a wide range of other legal services. If you want a better idea of how we can help you run an investment fund in Hong Kong, do not hesitate to reach out to us.
Why is there a high demand for investment fund lawyers in Hong Kong?
Hong Kong has always been a financial hub, but the expansion of international trade as well as rapidly changing Hong Kong regulations mean that an experienced fund lawyer is crucial to the successful management of investment funds.
What specific legal due diligence do investment fund lawyers perform during a fund investment process?
Our investment fund lawyers conduct thorough due diligence to mitigate potential risks. This includes reviewing target company contracts, assessing intellectual property rights, analysing regulatory compliance, examining financial records, and identifying potential litigation or liabilities. We also consider the legal structure of the target investment to ensure it aligns with the fund's strategy and complies with applicable laws. This meticulous approach can protect your assets and ensure informed decision-making.
How can investment fund lawyers assist with the negotiation and drafting of investment management and advisory agreements?
Investment management and advisory agreements are integral in determining the relationship between fund managers and investors. Our lawyers specialise in negotiating and drafting these agreements to protect your interests. We ensure clarity on fee structures, performance benchmarks, liability limitations, termination clauses, and dispute resolution mechanisms.
How are funds regulated in Hong Kong?
All public funds in Hong Kong are regulated by the Securities and Futures Commission (SFC). Other than this, many private equity fund managers operate out of Hong Kong.
Frequently asked questions
Do I need a family office in Hong Kong?
You need one if you are managing significant private wealth across investments, property, and businesses, and want a dedicated structure to hold, govern, and pass it on, rather than running it through personal or operating-company accounts. Hong Kong is especially attractive if your family, business or investments touch Greater China and Asia, and if you want to benefit from the family office tax concession. We help you decide whether a full single-family office, a lighter holding structure, or a multi-family office arrangement fits.
What is the Hong Kong family office tax concession?
It is a profits-tax concession that can apply a 0% rate to qualifying investment gains of an eligible Family-owned Investment Holding Vehicle (FIHV) managed by a single-family office in Hong Kong, subject to conditions on ownership, minimum assets and local substance. In practice, it may, subject to meeting all qualifying conditions in force at the relevant time, allow a properly structured family office to hold and grow investment assets in Hong Kong tax-efficiently; note that a Bill currently before the Legislative Council proposes changes to these conditions. We advise on whether your structure qualifies and design it to meet the criteria.
What is a FIHV and how does it relate to my family office?
A FIHV (Family-owned Investment Holding Vehicle) is the investment-holding entity through which the family’s assets are held and managed, and it is the vehicle that can access the tax concession when managed by an eligible single-family office. The family office is the management and decision layer; the FIHV is the holding layer. We structure both, and the relationship between them, so the concession conditions are met.
How much wealth do you need to set up a family office?
There is no fixed legal minimum to form the structures. Still, the tax concession and the cost of a full single-family office mean it typically makes commercial sense at a substantial level of investable assets given the current HK$240 million asset threshold for the FIHV concession. Many families start with a holding and trust structure and build toward a full family office as wealth and complexity grow. We size the structure to your assets rather than pushing a one-size-fits-all model.
Single-family office vs multi-family office — which do I need?
A single-family office (SFO) serves one family exclusively and may access the tax concession where it meets the qualifying conditions; a multi-family office (MFO) serves several families and is generally a licensed service provider. If you have the scale and want full control and confidentiality, an SFO usually fits; if you prefer to share infrastructure and cost, an MFO may suit. We advise families on both, and we also act as counsel to MFOs establishing structures for their clients.
How are digital assets held in a family office?
Digital and virtual assets can be held within the family office structure through carefully chosen entities, with close attention to custody, private-key control, legal title, and how the assets are characterised for regulatory and tax purposes. The key legal questions are custody and control, succession (who can access the assets if something happens to the holder), and whether any given activity triggers Hong Kong’s virtual-asset regime, a determination made on a case-by-case basis by reference to the SFC’s dual licensing framework for virtual asset trading platforms and service providers.
How do we plan succession across borders?
Cross-border succession planning combines trusts, wills and holding structures to control how assets pass on, reduce (though not necessarily eliminate) the risk of forced-heirship or multiple-probate complications, and help keep the transition private. The aim is to avoid assets being frozen, disputed or taxed inefficiently when they cross borders on death. We coordinate the Hong Kong elements and work alongside your advisors in other jurisdictions to keep the plan consistent.
How do we keep the family’s wealth separate from the operating business?
By holding investment assets in a dedicated family office / FIHV structure that is legally distinct from the operating company, so business risk, family disputes and succession events do not contaminate each other. This separation protects the family’s wealth from operating-business liabilities and makes governance and succession far cleaner. We design the entity layering and the trust and shareholding arrangements that create it.
What is a family constitution, and is it legally binding?
A family constitution (or charter) sets out how the family makes decisions, appoints leaders, resolves disputes and passes wealth between generations. Parts of it can be given legal effect through the underlying trust deeds, shareholder agreements and company constitutions; other parts operate as a shared statement of principles. We draft the constitution and align it with the binding documents so it is enforceable where it counts.
Can a family office help avoid family disputes?
Good structuring and governance significantly reduce the risk of disputes by making roles, rights, distributions and succession explicit before problems arise. Clear trust terms, a family constitution and defined decision-making and exit mechanisms remove much of the ambiguity that fuels conflict. Where disputes do arise, the right structure makes them faster and more discreet to resolve.
What does it cost and how long does setup take?
It depends on the number of entities, the trust and succession elements, and whether you are seeking the tax concession. How many jurisdictions are involved matters too — a straightforward structure moves quickly, while a multi-generational, multi-jurisdiction setup takes longer. We scope the work and give you a clear estimate up front rather than an open-ended engagement, and we focus on doing the setup once, properly, so it lasts.
Does TITUS run or administer the family office day to day?
No. TITUS acts as legal and structuring advisor, not as the day-to-day administrator or asset manager. We design and implement the structure, secure the tax and regulatory footing, and provide ongoing legal counsel, then coordinate with your chosen administrators, bankers, accountants and investment managers. This keeps us independent and focused on protecting the legal integrity of the structure.
What regulatory or licensing issues apply to a Hong Kong family office?
Whether a single-family office serving one family requires a licence from the Securities and Futures Commission depends on whether its activities constitute a regulated activity carried on as a business in Hong Kong; a single-family office that is not carrying on business for profit will generally fall outside the licensing requirement, whereas multi-family offices or those serving third parties usually require a licence. AML, KYC and reporting obligations also apply depending on the structure. We assess your activities against Hong Kong’s regulatory perimeter and structure the office to stay on the right side of it.
We’re first-time founders after a liquidity event — where do we start?
Start by separating the newly liquid wealth from the operating business and putting a holding and succession structure in place before the money is deployed or distributed. Early structuring protects the proceeds, may help position you for the tax concession (subject to meeting the applicable qualifying conditions), and can address both traditional and digital-asset wealth in one plan. We work at the speed liquidity events demand, so the structure is ready when the capital lands.
Email info@titus.com.hk · WhatsApp +852 9702 3003 · Tel +852 3702 0045
This page is general information about our services and does not constitute legal or tax advice, nor a solicitation. The law and tax rules described are subject to change; obtain specific advice before acting.