Hong Kong Property Stamp Duty: A Complete Guide for Buyers and Investors

Introduction

Stamp duty is one of the most significant transaction costs in Hong Kong property purchases. Over the years, the Hong Kong Government has progressively introduced additional stamp duties to cool the property market and manage demand from overseas and investor buyers. In 2024, the Government announced a substantial relaxation of these measures, reducing or eliminating several of the demand-side management duties.

Understanding the current stamp duty regime is essential for anyone purchasing or investing in Hong Kong residential or non-residential property. This guide explains all applicable duty types, current rates, exemptions, and the impact of the 2024 policy changes.

Types of Property Stamp Duty in Hong Kong

Hong Kong property transactions may attract up to four types of stamp duty:

1. Ad Valorem Stamp Duty (AVD) – the base duty on all property transactions;
2. Buyer’s Stamp Duty (BSD) – additional duty applicable to non-permanent residents;
3. New Residential Stamp Duty (NRSD) (formerly known as Double Stamp Duty / DSD) – additional duty on residential property acquisitions (with exemptions);
4. Special Stamp Duty (SSD) – duty on residential property resold within a specified holding period.

Ad Valorem Stamp Duty (AVD)

AVD applies to all Hong Kong property transactions (residential and non-residential). Two scales apply:

Scale 1 – Standard Rate

Scale 1 applies to non-residential properties and to residential purchases by companies or by permanent residents who already own residential property in Hong Kong. Rates are progressive, from 1.5% on properties up to HKD 2 million to 8.5% on properties above HKD 21,739,120 (as at 2025).

Scale 2 – Concessionary Rate

Scale 2 applies to Hong Kong Permanent Residents (HKPRs) purchasing their first residential property (where they do not concurrently own any other residential property in Hong Kong). Rates range from HKD 100 on properties up to HKD 2 million to 4.25% on properties above HKD 21,739,120.

To qualify for Scale 2, the purchaser must:

• Be a Hong Kong permanent resident (HKID holder with the right of abode);
• Be purchasing the property in their own name (not through a company);
• Not own any other residential property in Hong Kong at the time of the transaction.

If a HKPR purchases a property in joint names with a non-HKPR, Scale 1 AVD applies to the entire transaction.

Buyer’s Stamp Duty (BSD)

Pre-February 2023 Position

BSD was introduced in October 2012 at a flat rate of 15% on the purchase price or market value (whichever is higher) of all residential properties purchased by:

• Persons who are not Hong Kong permanent residents;
• Companies (regardless of where incorporated).

BSD was payable in addition to AVD, resulting in a combined duty of up to 23.5% for foreign buyers.

2024 Policy Change: BSD Abolished for All Buyers

In the 2024-2025 Budget Speech and subsequent policy announcement, the Hong Kong Government announced the abolition of BSD with effect from 28 February 2024 for all residential property purchases, including purchases by non-permanent residents and companies. This was a landmark policy reversal after over a decade of BSD application.

From 28 February 2024, non-HKPR individuals and companies purchasing residential property in Hong Kong are subject only to AVD at Scale 1 rates (no BSD, no NRSD), significantly reducing the transaction cost for overseas buyers.

New Residential Stamp Duty (NRSD)

History

NRSD (previously called Double Stamp Duty or Additional Stamp Duty) was introduced in phases from 2013 and applied at a flat rate of 15% on residential property purchases by Hong Kong permanent residents who already own residential property, or by any company. Combined with AVD at Scale 1, this resulted in a total duty of up to 23.5% for investors who already own property.

2024 Policy Change: NRSD Abolished

NRSD was also abolished with effect from 28 February 2024. From this date, Hong Kong permanent residents who already own residential property are subject only to AVD at Scale 1 rates on further residential acquisitions. The effective abolition of both BSD and NRSD has materially reduced stamp duty costs for second-property buyers and investors.

Special Stamp Duty (SSD)

SSD remains in force and applies to residential properties resold within a specified holding period from the date of acquisition. SSD is designed to deter short-term speculative flipping and applies regardless of the buyer’s residency status.

SSD Rates (as at 2025)

• Resold within 6 months: 20% of the resale price or market value (whichever is higher);
• Resold after 6 months but within 12 months: 15%;
• Resold after 12 months but within 24 months: 10%;
• Resold after 24 months: No SSD.

SSD is calculated on the resale consideration or market value, whichever is higher, and is payable by the seller. SSD applies only to residential properties; commercial and industrial properties are not subject to SSD.

SSD Exemptions

Certain transactions are exempt from SSD:

• Disposal by a deceased person’s estate under a grant of probate;
• Disposal to the Government or a government body;
• Disposal pursuant to a court order;
• Disposal of a property acquired by a mortgagee in possession;
• Disposal of a property received as a gift from a close relative (subject to conditions).

Stamp Duty on Non-Residential Properties

Commercial properties (offices, shops, industrial units) in Hong Kong are not subject to BSD, NRSD, or SSD. Only AVD at Scale 1 rates applies. This makes commercial property investment significantly less stamp-duty-intensive than residential investment, even for foreign buyers and companies.

Stamp Duty for Company Share Transfers

Where a property is owned by a company and the shares of that company are transferred (rather than the property itself), stamp duty is assessed differently:

• Share transfer stamp duty at 0.2% applies to the transfer of shares (0.1% on the sale contract and 0.1% on the transfer instrument);
• However, the SFC/IRD have anti-avoidance powers and may assess the transaction on the value of the underlying property if they view the share transfer as a disguised property transfer.

Legal and tax advice should be obtained before structuring a property acquisition through a company share purchase, particularly in light of anti-avoidance rules.

Stamp Duty Payment Timing

Stamp duty is payable within specified timeframes:

• AVD and BSD – within 30 days of the date of the agreement for sale and purchase (PASP or ASP);
• NRSD – same as AVD;
• SSD – within 30 days of the disposal (sale).

Late payment attracts a surcharge of up to 10 times the original duty, plus interest. Stamp duty is assessed and collected by the Stamp Office of the Inland Revenue Department (IRD).

Practical Implications of the 2024 Changes

The abolition of BSD and NRSD in February 2024 has had significant implications for the Hong Kong property market:

• Overseas buyers – non-HKPR individuals and companies now face only AVD at Scale 1 rates, materially reducing the barrier to property investment;
• HKPR investor-buyers – existing HKPR property owners can now purchase additional properties at Scale 1 AVD only, without the additional 15% NRSD;
• Corporate structures – the tax advantage of using corporate structures to hold residential property has diminished since companies now also only pay AVD at Scale 1;
• Market activity – the policy relaxation was intended to stimulate a market that had seen significant price corrections since 2022; its effect on transaction volumes and prices has been closely monitored.

How Alan Wong LLP Can Assist

Alan Wong LLP’s Corporate & Commercial and Property teams advise buyers, sellers, investors, and developers on all aspects of property stamp duty in Hong Kong. Our services include:

• Stamp duty assessment and planning for residential and commercial property transactions;
• Structuring advice for property acquisitions, including corporate holding structures and stamp duty implications;
• Conveyancing services for Hong Kong property purchases and sales;
• Advice on SSD exemptions and IRD stamp duty disputes;
• Review of stamp duty treatment for cross-border property investment structures.

Contact us to discuss the stamp duty implications of your property transaction.