Country guide · Germany

Hong Kong Offshore Company for Residents of Germany

Last updated · Reviewed by the Harbourline Corporate compliance team

Short answer: German residents can own and direct a Hong Kong company and incorporate it 100% online. Hong Kong will not tax profits sourced outside Hong Kong. However, Germany may tax the company or its owners under its own residence (management and control) and CFC rules, so the Hong Kong 0% is only part of the picture. German founders who emigrate or manage the company from abroad can benefit most; residents should obtain a Steuerberater opinion on place of management.
Key facts
Can German residents incorporate?Yes — fully online, no visit needed
Hong Kong tax on offshore profits0%
Home-country rules to checkCompany residence (management) + CFC
Information exchangeBank accounts reported under CRS / FATCA

How Hong Kong taxes a company owned from Germany

Hong Kong taxes on a territorial basis. Where the owner lives does not affect Hong Kong tax. If the company earns its profits outside Hong Kong, it can claim offshore status and pay 0% Hong Kong Profits Tax, and there is no Hong Kong withholding tax on dividends paid to you.

Germany rules you must consider

A company whose place of effective management (Ort der GeschĂ€ftsleitung) is in Germany is subject to German corporate and trade tax. The German Außensteuergesetz (AStG) CFC rules can attribute low-taxed passive income of a foreign company to German-resident shareholders. The low-tax threshold is currently below 15%. Active trading and service income is generally not passive income under the AStG, but the classification needs careful review. German tax residents also pay tax on the dividends they receive.

Setting up from Germany

Open your client portal, choose three company names, pay online and verify your identity with your passport through our online KYC. We handle the rest, including a licensed company secretary and a registered Hong Kong address. See the full non-resident formation guide.

Frequently asked questions

Can a German citizen own a Hong Kong company?

Yes. Hong Kong allows 100% foreign ownership and a single foreign director with no residency requirement.

Will Germany tax my Hong Kong company?

Possibly. Germany may treat the company as resident if it is managed from there, and CFC rules may attribute some income to you. Get advice from a qualified German tax adviser.

Official sources

This guide is general information, not tax or legal advice. Hong Kong offshore status is decided by the Inland Revenue Department on the facts of each case, and your country of residence may tax you or the company.