Wealth management in Hong Kong

“Alexis, I'm moving to Hong Kong to run the Asia subsidiary. I'll pay almost no tax there. Does that settle my French tax?”

Not automatically. Hong Kong taxes only income sourced there, and that is precisely what makes your resident status hard to establish under the France–Hong Kong tax agreement. It has to be proven; it is not presumed.

Hong Kong and Macao have 9,943 French nationals on the consular register as of 31 December 2025, an almost stable figure (−0.6% over one year).

The applicable text is the agreement of 21 October 2010, separate from the treaty with China : applying the Chinese text to a Hong Kong file is a common mistake. It covers income and wealth, but not estates. At Balmont Conseil, we start from this text, read together with its protocol.

1. Why seek expert wealth management in Hong Kong?

Four points determine your situation.

Residence is proven by days. The protocol to the agreement defines a Hong Kong resident: habitual residence, or more than 180 days in a year of assessment, or more than 300 days over two consecutive years. The count must be kept as you go, not reconstructed.
The certificate is not enough. The Hong Kong tax authorities issue a certificate of residence, but state themselves that it does not guarantee the benefits of the agreement. Resident status is defended with a complete file.
The exit tax requires guarantees. Hong Kong does not assist France in collecting tax: the deferral must be requested, with a tax representative in France.
Your estate. No convention governs it: France applies article 750 ter of the general tax code, without conventional correction.

2. The France ↔ Hong Kong framework in five verified points

Here is the applicable framework, checked against official sources as at 1st October 2026.

French nationals on the register	9,943 as of 31 December 2025, Macao included (−0.6% over one year).
Income tax treaty	Yes — agreement of 21 October 2010, in force since 1st December 2011, separate from the treaty with China. It covers income tax and wealth tax, and therefore the IFI.
Estate tax treaty	No. No text regulates inheritances or gifts between France and Hong Kong: Article 750 ter of the General Tax Code applies without conventional correction.
Exit tax — deferral of payment	Deferral on request, with a tax representative and guarantees. Hong Kong does not assist France in collecting tax (annex BOI-ANNX-000508).
CSG and CRDS on property income and capital gains	17.2% on property income and property capital gains, 18.6% on furnished lettings from 2025 income. The reduced rate of 7.5% does not apply.

Sources: list of tax treaties concluded by France (BOI-ANNX-000306, updated 29 April 2026); exchange-of-information and recovery-assistance clauses (BOI-ANNX-000508, position at 8 October 2025); register of French nationals living outside France at 31 December 2025 (Ministry for Europe and Foreign Affairs); text of the treaty published by impots.gouv.fr; impots.gouv.fr for non-residents' social charges. Position as at 1st October 2026.

On residence. Article 4(1) in principle excludes persons taxed in a territory only on their locally sourced income; the protocol sets this exclusion aside for Hong Kong's ordinary tax system, but not for offshore regimes. Lease, identity card, Hong Kong tax returns and immigration records should be gathered from the day you arrive.

On your French income. They remain taxed in France: minimum rate of 20%, then 30% above €29,579 of net taxable income, or the average rate if more favourable, and social charges at the full rate.

On the IFI. The agreement covers wealth tax: it governs the IFI due on your property located in France above €1.3m.

What we do not show. Details of Hong Kong tax are handled with a licensed adviser on site, whom we coordinate.

3. Our services: 360° support for expatriates and investors

Three workstreams, in the order in which they are decided.

The exit tax and the residence file

We calculate your unrealised capital gains and test the thresholds of Article 167 bis of the French Tax Code, then put together the deferral file. At the same time, we list the documents that will prove your Hong Kong residence, and the day count to keep.

Valuation of unrealised capital gains and deferral file.
Count of the 180 and 300 days, residence documents.
French tax departure date.

Your French income and contracts as seen from Hong Kong

Rents, dividends, assurance-vie: we establish what France continues to tax and what the agreement reduces. A French assurance-vie held by a non-resident no longer bears social charges; its withdrawals are subject to a 12.8% levy, or 7.5% after eight years.

For long-term mobility, a Luxembourg assurance-vie contract may be considered, case by case.

Estate transfer without a treaty

We establish what each heir would pay in France, according to their residence and the situation of the assets, and we prepare the gifts before departure.

4. Methodology: our way of working

We work in four stages, and at each stage you know where you stand.

The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.

5. What the firm offers you

What concretely sets our work apart.

Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.

Frequently asked questions — Hong Kong

Which treaty applies to Hong Kong: the one with China?

No. Hong Kong has its own agreement with France, signed on 21 October 2010 and in force since 1st December 2011. The France–China treaty of 26 November 2013 does not apply to a Hong Kong resident.

How can I prove that I am a resident of Hong Kong?

The protocol to the agreement uses habitual residence, or more than 180 days' presence in a year of assessment, or more than 300 days over two consecutive years. The Hong Kong tax authorities' certificate of residence helps, but they state that it does not guarantee the benefits of the agreement.

Is the exit tax deferral automatic for Hong Kong?

No. Hong Kong does not assist France in collecting tax (annex BOI-ANNX-000508). The deferral must be requested, with a tax representative and guarantees (Article 167 bis of the French Tax Code).

Is my French rental income still taxed in France?

Yes: at a minimum rate of 20% up to €29,579 of net taxable income and 30% above that, unless you opt for the average rate, plus social charges of 17.2% on unfurnished lettings and 18.6% on furnished lettings from 2025 income.

Will my estate be taxed in France?

For your assets located in France, yes, and for all assets received by an heir domiciled in France for at least six of the last ten years (Article 750 ter of the French Tax Code). No text governs estates between France and Hong Kong.

In summary

Hong Kong's light taxation does not, on its own, settle your French tax: residence must be proven, the exit tax requires guarantees, and no text protects your estate.

These three points are prepared before departure, together with the treatment of your French income and contracts.

Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.