Who’s covered, and who isn’t

Almost every employee in Hong Kong aged 18 to 64, in continuous employment for 60 days or more, has to be enrolled in an MPF scheme — there’s no minimum-hours or full-time test the way there is in some other jurisdictions. Below HK$7,100 a month in relevant income, the employer still has to contribute 5% on the employee’s behalf, but the employee isn’t required to make a matching contribution, though they can choose to.

Casual employees in construction and catering sit under a different rule: rather than the standard 60-day enrolment window, they need to be enrolled within 10 days, usually through the employer’s Industry Scheme rather than a standard MPF scheme, reflecting how short-term and project-based that work tends to be.

The relevant-income band itself is capped at both ends. Below HK$7,100 the employee side is optional; above HK$30,000 a month, both employer and employee contributions are capped at HK$1,500 each, regardless of how much higher the employee’s actual salary runs.

A HK$30,000 cap that’s been under review since 2026

The HK$30,000 maximum relevant income level, and the HK$1,500 contribution cap that comes with it, have been unchanged since 1 June 2014. In early 2026, the Mandatory Provident Fund Schemes Authority (MPFA) began reviewing an increase — reportedly to a HK$40,000 maximum relevant income and a HK$2,000 monthly cap per party, alongside a possible rise in the HK$7,100 minimum income floor.

As of the most recent public reporting, this remains a proposal under review, with a report expected around the middle of 2026 and no confirmed effective date. Employers with higher earners on payroll should watch for a formal announcement rather than assume either the current or the proposed figures will hold indefinitely — but for now, HK$30,000 and HK$1,500 remain the operative caps.

What employers need to get right each month

• Enrol every eligible new employee (18–64, 60 days or more of continuous employment) within 60 calendar days of their start date — 10 days for casual construction or catering staff
• Deduct 5% of relevant income from employees earning HK$7,100 or more a month, and contribute a matching 5% yourself, capped at HK$1,500 each once income reaches HK$30,000
• Still contribute your 5% for employees earning under HK$7,100 a month, even though their own contribution is optional
• Pay both employer and employee contributions to the scheme trustee by the 10th day of the following month, to avoid the 5% default surcharge and financial penalties

A discount every company must ask for, capped once per group

The mechanics are simple for a standalone company. A company with HK$3 million of assessable profits pays 8.25% on the first HK$2 million (HK$165,000) and 16.5% on the remaining HK$1 million (HK$165,000), for total tax of HK$330,000 — against HK$495,000 if the full amount were taxed at the standard 16.5% rate. That’s the maximum the two-tiered regime can save any single taxpayer: HK$165,000 a year. What catches companies out is that the discount isn’t automatic just because a company qualifies for it. Inland Revenue Department guidance confirms that even a company with no connected entities has to declare in its Profits Tax Return that it is chargeable at the two-tiered rates.

The one-per-group cap is where it gets stricter. Two entities are “connected” if one holds, directly or indirectly, more than 50% of the other’s shares, voting rights or entitlement to profits, or if both are held that way by the same parent or individual. That definition catches sister companies under common ownership even when neither holds shares in the other, and it treats a sole proprietor’s separate unincorporated businesses as connected to each other too. Only one entity in that connected group may elect the two-tiered rates for a given year; every other connected entity pays the standard 16.5% (or 15%, for unincorporated businesses) on the whole of its profits that year, not just the amount above HK$2 million.

The nominated entity makes the election by declaring, in its own Profits Tax Return, that it is chargeable at the two-tiered rates and that no other connected entity has elected the same treatment for that year. Once filed, that election is irrevocable for the year of assessment it covers — but it isn’t a permanent choice for the group. A different connected entity can be nominated in a later year’s return, which is worth revisiting whenever profits shift between group companies, since the saving is only worth the full HK$165,000 if the nominated entity actually earns at least HK$2 million that year.

For a group with several Hong Kong entities, VIVOS Corporate Services (HK) Ltd. reviews profit forecasts across the group before each return is due, so the election lands on the entity that will actually use it in full, and is filed correctly and on time.

Where the new global minimum tax fits in

Hong Kong’s Pillar Two rules — the Income Inclusion Rule and the Hong Kong Minimum Top-up Tax — took effect for accounting periods beginning on or after 1 January 2025, but they only reach multinational enterprise groups with global annual revenue of at least EUR750 million. For every other Hong Kong business, the two-tiered profits tax rates above remain the whole story.

A private register, but not an optional one

The Significant Controllers Register (SCR) has applied to every Hong Kong private company since 2018, regardless of whether the shareholders are local or overseas, and regardless of company size. It’s easy to assume it only matters for companies with complex or foreign ownership — it doesn’t. A wholly Hong Kong-owned company with two shareholders still needs one.

The 25% threshold covers shares and voting rights, but it isn’t the only way to qualify. A person who can appoint or remove a majority of the board is a significant controller even without owning shares directly, and so is anyone who “exercises significant influence or control” over the company in practice — the Companies Registry’s own guidance gives the example of a founder who has stepped back from formal shareholding or a director role but still drives the company’s key decisions.

Every company also needs at least one designated representative on file — someone who can respond to a law enforcement request about the register. This can be a Hong Kong-resident director, employee or shareholder, or a licensed accounting or legal professional, or a trust and company service provider such as a corporate secretarial firm. A significant controller can act as their own designated representative if they meet the residency and role requirements.

One detail that trips companies up: the SCR is never filed with the Companies Registry for public search. It stays at the registered office, or at another Hong Kong address the company has notified on Form NR2, and is only produced when a law enforcement officer asks to inspect it. That privacy is exactly why it’s easy to let the register drift out of date — nothing external prompts an update the way an annual return does.

Because the SCR needs to reflect reality at all times, not just once a year, it works best as part of ongoing corporate secretarial administration rather than a one-off filing. VIVOS Corporate Services (HK) Ltd. maintains SCRs as a standard part of its corporate secretarial service, so a change in shareholding or control gets picked up and recorded as it happens, not discovered at the next audit.