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BVI/Cayman and ESR
Content date: 2026-08-24
ESR
Pure holding companies often face a reduced substance test. Licensed activity, headquarters functions or relevant income usually require local people, expenditure and decision records, per the rules then in force.
Case-specific decisions differ — book a consultation with our advisers.
The content of this page is general professional information and does not constitute tax, legal or investment advice. For specific cases, please consult a Hong Kong practising accountant or tax adviser, or refer to official publications of the IRD / SFC / HKMA / CR.