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GuideCompany formationHong Kong

Hong Kong or Singapore for an Asian holding company

Both are credible common-law jurisdictions with different substance expectations. The choice usually comes down to where your people and counterparties actually are.

What the two have in common

Both are common-law jurisdictions with English-language documentation, share-capital companies, mandatory company secretaries and a local registered office. Both expect real corporate administration rather than a dormant shell.

Where they diverge

Singapore requires at least one director ordinarily resident in Singapore. If your team has none, that requirement has to be solved through a provider arrangement before incorporation, and it is a continuing obligation.

Hong Kong has no resident-director requirement, but most operating companies prepare audited statutory accounts, which changes the annual cost and effort profile.

  • Resident director: required in Singapore, not required in Hong Kong
  • Annual audit: expected for most Hong Kong operating companies
  • Registers: significant controllers register in Hong Kong, register of registrable controllers in Singapore
  • Registry administration: both electronic; Singapore's is tightly standardised

How to decide

Start from operations rather than from the jurisdiction. Where are the people who will sign contracts, where are the customers, and which market will the subsidiaries sit in?

A holding company placed where nobody works creates substance questions later, in both jurisdictions and in the countries where the subsidiaries operate.

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