Hong Kong Tax Lawyers: M&A, Cross-Border and Fund Tax Structuring

Slotine advises private companies, family offices, private equity funds and technology businesses on Hong Kong tax structuring, from M&A and cross-border planning to Hong Kong’s concessionary regimes. Boutique law firm. Tax built into the transaction, not around it.

Multilingual (English, French, Cantonese). Cross-border via our international network. Direct partner access. Fee proposals within a few working days.

Hong Kong’s territorial tax system and its treaty network are the reason many transactions and investment structures anchor here. The rules that shape those transactions have moved fast: the family office concession in May 2023, the patent box in July 2024, a digital Certificate of Resident Status for the Mainland in November 2025, and a 2026 Bill in progress to broaden the carried interest regime.

For advisers and in-house teams, that pace makes tax a live workstream at deal moment, not something to bolt on after signing. A well-structured Hong Kong holding, a properly elected patent box, a qualifying single family office or a certified fund manager can change the effective tax outcome by tens of percentage points. Getting it wrong, or getting it late, is expensive.

Slotine sits in the space where legal structuring and tax meet. We advise on the entity choice, the substance, the certification and the treaty position at the same time as the transaction documents, because those decisions are inseparable in practice.

Four phases, calibrated to the mandate size. Tax mandates run alongside our M&A, private equity and family office work.

Six domains where our tax practice runs day to day. Each connects into the transactions we run, so the tax analysis and the documents move together.

Three years of concessionary regimes and one Bill in progress. This is the terrain we work in.

Families and businesses rarely sit in one place. Our tax practice coordinates the Hong Kong structure with the positions that matter across the client’s footprint.

Tax mandates vary enormously in size, from a single CoR application to a full family office setup or a cross-border acquisition. We scope each engagement and agree the fee basis in writing before we begin.

Advisory memos and second opinions are typically delivered in one to three weeks, on a fixed or capped fee.

CoR applications track the IRD’s 21 working day target, plus preparation time for the beneficial owner analysis and supporting documents.

Family office setups and FIHV/FSPE elections run alongside the corporate formation, typically several weeks between mandate and first tax filing, on a scope-based fee.

Carried interest structuring, patent box elections and M&A tax structuring are integrated into the underlying transaction timeline. Fees are proposed after scoping, on a fixed or capped basis where possible.

Boutique focus. A small partnership, direct partner access, no juniorised handling. Tax is one of a small set of practice areas we run at depth, not an add-on service.

Legal and tax integrated. Our tax analysis moves with the M&A, private equity, family office and IP work rather than sitting in a separate compliance stream. The tax outcome is settled inside the transaction, not around it.

Cross-jurisdictional practice. Hong Kong and European reach coordinated within one relationship, through our international network, rather than a series of unmanaged referrals.

Published depth. A body of practitioner guides on the FIHV regime, the patent box, carried interest and treaty relief stands behind the advice.

Written fee proposals. Every engagement is scoped and priced in writing before we start. Fixed or capped fees where the scope allows.