Capital Investment Entrant Scheme (CIES): Hong Kong Investor Immigration Guide 2024–2025

Introduction: Hong Kong's Investor Immigration Pathway

Hong Kong relaunched its Capital Investment Entrant Scheme (CIES) on 1 March 2024, replacing the previous scheme that was suspended in 2015. The revamped CIES provides a dedicated pathway for high-net-worth individuals to obtain Hong Kong residency by making a qualifying investment of HK$30 million in prescribed asset classes.

The CIES is particularly attractive to investors who seek to establish a base in Hong Kong for business, investment, and family reasons, without the employment requirements of the General Employment Policy (GEP) or the career focus of the Quality Migrant Admission Scheme (QMAS). It is designed to attract mobile capital and entrepreneurial talent to Hong Kong's economy.

Who Is Eligible?

To be eligible for the CIES, an applicant must:

• Be 18 years of age or above
• Not be a national of Afghanistan, Cuba, or the Democratic People's Republic of Korea (the three excluded nationalities)
• Have a net investment portfolio of not less than HK$30 million held in qualifying assets throughout the application period
• Not have any criminal conviction in Hong Kong or overseas
• Have acceptable financial standing and assets legitimately obtained

There is no requirement to be in employment, to have a specific educational qualification, or to score points on any assessment system. The scheme is open to nationals of any country (save the three excluded nationalities) regardless of their current country of residence.

PRC nationals who are permanent residents of a third country (other than Macau) may apply if they hold a valid travel document of that third country. PRC nationals who are not third-country permanent residents must apply through separate mainland China channels rather than the CIES.

The HK$30 Million Investment Requirement

Permissible Investment Assets

The HK$30 million qualifying investment must be made in one or more of the following prescribed asset classes:

1. Financial assets (must comprise at least HK$27 million, i.e., 90% of the qualifying portfolio):

• Equities listed on HKEX (including shares and REITs)
• Debt securities listed on HKEX
• Certificates of deposit issued by licensed banks in Hong Kong
• Subordinated debt issued by licensed banks
• Eligible collective investment schemes (including SFC-authorised unit trusts and mutual funds, and SFC-authorised ETFs)
• Limited partnership funds registered with the Limited Partnership Fund Registry in Hong Kong
• Non-listed equities of companies incorporated in Hong Kong

2. Hong Kong Investment Portfolio through an eligible single family office or investment manager (at least HK$3 million of the portfolio must be allocated to a specially curated “Innovation and Technology” (I&T) fund managed by a licensed HK investment manager)

3. Real estate: Residential or commercial real estate in Hong Kong valued at no more than HK$10 million (if any) may count towards the HK$30 million threshold, but not more than HK$10 million of the total may be in real estate.

Valuation

All assets must be valued at the prevailing market value at the time of application. The applicant must demonstrate that the full HK$30 million qualifying portfolio has been held for at least two years before the date of application (or established within six months prior to application for new investments made specifically for CIES purposes).

The Application Process

Step 1: Obtain Eligibility Assessment

Before investing, applicants should seek a formal eligibility assessment from the Immigration Department (ImmD). The assessment application is submitted online via the ImmD's CIES portal, with supporting documents including: proof of identity (passport), proof of assets (bank statements, investment account statements, property valuations), source of funds documentation, and a declaration of no criminal convictions.

ImmD will assess whether the applicant meets the eligibility criteria. A positive assessment does not guarantee visa approval but confirms that the applicant may proceed to the investment stage.

Step 2: Make the Qualifying Investment

After obtaining a positive eligibility assessment, the applicant makes the qualifying investment of at least HK$30 million in permissible assets. The investment must be managed through an SFC-licensed institution (bank or investment manager) that has been approved by ImmD as a Certified Management Institution (CMI) for CIES purposes.

The CMI provides ongoing management of the portfolio and is responsible for monitoring compliance with the investment conditions throughout the applicant's stay in Hong Kong.

Step 3: Submit Visa Application

The formal visa application is submitted to ImmD, accompanied by: proof of the qualifying investment (CMI confirmation), a business plan (required for applicants with non-financial asset portfolios), personal information, and application fees. The application fee is HK$10,350 per applicant (2024 rate).

ImmD aims to process straightforward applications within 6 to 8 weeks. Complex applications (e.g., those involving verification of overseas assets or source of funds) may take longer.

Step 4: Entry Permit and Residency

Upon approval, the applicant is granted an Entry Permit allowing them to reside in Hong Kong for a period of 24 months (2 years). Dependants (spouse and unmarried children under 18) may accompany or join the main applicant under a separate dependant visa.

The CIES holder must continue to hold the qualifying investment of at least HK$30 million throughout their stay in Hong Kong. Any reduction below the threshold must be remedied within a specified period.

Extension of Stay and Permanent Residency

Extension

CIES holders may apply for extension of stay, initially for 3 years and subsequently for 3 years at a time, provided they continue to hold the qualifying investment and remain in Hong Kong for the required period.

Right of Abode (Permanent Residency)

CIES holders become eligible to apply for the Right of Abode (permanent residency) in Hong Kong after residing in Hong Kong continuously for 7 years. The 7-year ordinary residency requirement applies to the CIES holder and their dependants. Permanent residents are not required to maintain the qualifying investment after obtaining the Right of Abode.

Hong Kong permanent residents enjoy the right to live and work in Hong Kong indefinitely, and are entitled to a Hong Kong Permanent Identity Card and, after the prescribed period, a HKSAR passport.

Tax Considerations for CIES Applicants

Hong Kong's territorial tax system means that income and gains from offshore sources are generally not subject to Hong Kong tax. CIES investors holding a diversified global investment portfolio through Hong Kong should not face significant Hong Kong tax exposure on their offshore investments.

Income derived from Hong Kong sources (dividends from Hong Kong-listed shares, interest on Hong Kong bank deposits, rental income from Hong Kong property) is subject to Hong Kong profits tax (at the standard rate of 16.5% for corporations) or salaries tax. However, there is no capital gains tax on disposal of Hong Kong investments.

CIES applicants with connections to other jurisdictions (particularly the US, UK, or Australia) should seek tax advice on the interaction between Hong Kong residency and their home country tax obligations before applying.

Comparison with Other Hong Kong Residency Pathways

The CIES complements other Hong Kong immigration schemes:

• QMAS (Quality Migrant Admission Scheme): Points-based system for skilled individuals; no minimum investment; requires employment or business establishment in Hong Kong
• IANG (Immigration Arrangement for Non-local Graduates): For recent graduates of Hong Kong universities; no investment requirement
• GEP (General Employment Policy): For individuals with confirmed employment offers from Hong Kong employers
• Top Talent Pass Scheme: For high-achieving talents from specified universities or high-income earners

The CIES is uniquely suited for individuals who have accumulated significant capital and wish to establish Hong Kong residency without the constraints of employment or points-based assessments.

Conclusion

The revamped CIES represents a significant opportunity for high-net-worth individuals seeking a transparent, straightforward pathway to Hong Kong residency. Hong Kong's tax efficiency, world-class financial infrastructure, geographic proximity to mainland China and Southeast Asia, and quality of life make it an attractive destination for investors and their families.

Early engagement with experienced immigration and investment advisers is essential to navigate the qualifying investment requirements, ensure compliance with ImmD conditions, and plan effectively for the long-term path to permanent residency.

Alan Wong LLP advises CIES applicants on investment structuring, immigration compliance, and estate planning in connection with Hong Kong residency. Contact us to discuss your application.