Hong Kong family office investment vehicles: funds and companies

Which investment vehicles can a Hong Kong family office use?

Families use four main building blocks: a holding company, a trust, a partnership and a fund. The tax concession for family-owned investment holding vehicles accepts a company, a partnership or a trust, including a discretionary trust, as the family vehicle (Inland Revenue Department, 2026). A separate private company can serve as the eligible single family office.

Start from the goal, not the vehicle. Ask what the family wants to control, what it wants to share among relatives and what it wants to keep private. Write the answers on one page, then match each goal to a vehicle. This order keeps the structure simple and easier to explain to a bank. A family that begins with a vehicle often ends with a structure that no one can describe in 2 minutes.

When does a holding company suit a Hong Kong family office?

A holding company suits a family that wants clear control and simple reporting. One owner or a small group holds the shares, the board takes decisions and the accounts show the assets in one place. Banks understand the structure, which helps with account opening and credit. Shares can pass to the next generation by transfer, and the board can add family members over time.

A company also serves as the eligible single family office, a private company managed or controlled in Hong Kong that provides services to the family vehicles for a fee. Keeping the office company apart from the holding company clarifies who employs the staff, who signs contracts and who bears the cost. That clarity helps at audit time and when a bank asks who runs the office.

How does a trust fit into a Hong Kong family office structure?

A trust separates legal ownership from benefit. A trustee holds the assets for named beneficiaries under a deed, and a discretionary trust lets the trustee decide who receives what within the terms. Families use trusts for continuity across generations and for clear rules on distributions.

The concession accepts a trust as a family vehicle, so a trust can sit inside the same structure as a company. The deed deserves careful drafting: define the beneficiaries, the powers of the trustee and the role of a protector. Review it whenever the family changes through birth, marriage or relocation. A trustee with local knowledge of Hong Kong and of the countries where the family lives adds practical value.

What is an open-ended fund company in a Hong Kong family office?

The open-ended fund company is a corporate form for investment funds that came into effect on 30 July 2018. It is a separate legal entity with variable share capital, a board of directors that owes statutory and fiduciary duties, assets held by a custodian and an investment manager licensed or registered with the Securities and Futures Commission (Wikipedia, open-ended fund company).

It can run as an umbrella fund with sub-funds, each with segregated assets and liabilities under a protected cell regime. A family that pools money from several relatives, or plans to admit outside investors, may find this form useful. A lawyer confirms whether the plan triggers a licence, and an accountant confirms how the fund reports to the family. Families with a long horizon also compare the running costs of a fund with those of a simple company.

Why would a Hong Kong family office choose a partnership?

A partnership lets several family members contribute capital under one agreement. The agreement fixes each partner’s share, the decision rules and the exit terms. The tax concession accepts a partnership as the family vehicle when the other conditions are met (Inland Revenue Department, 2026).

Partnerships fit families who want flexibility on profit sharing and on contributions over time. The cost of that flexibility is a longer agreement. Have a lawyer draft the document with clauses for death, divorce and disagreement, since a partnership reflects the relationships of the people who sign it. Agree the dispute process when relations are warm.

What role do family special purpose entities play in a Hong Kong structure?

A family special purpose entity sits below the family vehicle and holds a specific investment or group of assets. The concession applies at both levels, in proportion to the vehicle’s interest in the entity (Inland Revenue Department, 2026). A family may create one entity per asset class or per deal.

The benefit is separation: each entity has its own records, its own bank account and its own risk. The cost is administration. Keep a chart of the group, with owners, directors and purpose of each entity, and update it each year so advisers and banks see the same picture. Close any entity that has served its purpose, since a smaller group is easier to run.

Which 5 questions help a Hong Kong family pick its vehicle?

Use five questions: who owns the assets, who decides, who shares the returns, who joins later and what must stay private. A single owner who decides alone points to a company. A family that wants to admit outside investors later points to a fund. Several relatives who share returns point to a partnership or a fund. Continuity across generations points to a trust.

Test the shortlist against the tax concession, the licence perimeter and the cost of running each vehicle. A free 30-minute pre-diagnostic with EQOS Asia helps you place your case (EQOS Asia private page, 2026). This page is general information, not legal, tax or investment advice, as of October 2026.

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About the author

Stéphane Jambu

President, EQOS Forecast Asia

Stéphane Jambu leads EQOS Forecast Asia and works as a consultant in e-commerce, search visibility, and AI. LinkedIn profile