Submissions and Reports

The Chamber fully supports the Government’s efforts to streamline statutory processes in the Northern Metropolis (NM) through the introduction of dedicated legislation. We regard the NM as a key pillar in shaping Hong Kong’s future and advancing its long-term, high-quality socio-economic development under the National 15th Five-Year Plan. As a flagship initiative, it will play an important strategic role in deepening Hong Kong’s integration with the Greater Bay Area, while reinforcing its position as an international financial and innovation hub.
We welcome the Government’s proposed measures, including those aimed at enhancing the efficiency of planning and land administration, accelerating construction timelines, and facilitating smoother business operations. At the same time, we highlight several additional priority areas for the Government’s consideration, including strengthening international awareness and investment promotion, expediting project delivery and enhancing governance, advancing innovation-ready infrastructure, leveraging AI to develop a smart metropolis, incorporating sustainability benchmarks, and cultivating and empowering next-generation talent and stakeholders. Our submission underscores the importance of a comprehensive framework that ensures long-term commercial sustainability, while appropriately balancing the interests of investors, operators, and end-users of the NM mega-project.

Mandatory Provident Fund Schemes Authority (MPFA) proposed an introduction of a two-tier surcharge mechanism aimed at urging non-compliant employers to settle outstanding contributions and surcharges promptly, thereby enhancing protection of employees’ MPF rights. The Chamber fully supports the MPFA’s commitment to promoting timely MPF contributions. However, we have great reservation over the envisaged arrangement. In lieu of a rigid two-tier fixed penalty structure, we recommend introducing an interest-based surcharge mechanism, which would be more proportionate and equitable.

The Chamber welcomes the Consultation Paper's objectives of broadening the pool of companies eligible for listing in Hong Kong while maintaining strong investor protection and market confidence. The Chamber considers that the proposed measures, taken together, could further reinforce Hong Kong’s position as a leading international financial centre.

From an implementation perspective, we also highlight the importance of enhancing efficiency and clarity in the listing process without compromising regulatory standards. Our suggestions cover, amongst others, the potential benefits of facilitating threshold relaxations for overseas issuers and introducing closely supervised grace periods for minor, non‑material compliance matters, to improve market accessibility while safeguarding regulatory integrity.

The Chamber welcomes the Government’s proposals to enhance IP tax deductions - including allowing deductions for acquisitions of IP from associated companies and recognizing upfront lump sum licence fees as deductible expenses - to keep Hong Kong on par with, and preferably more favourable, than that of other competing regional IP trading centres, in particular Singapore, so as to reinforce the city’s positioning as a regional IP trading hub.

We also recommend that any safeguards against abuse of the proposed expanded tax exemptions should be necessary, proportionate and not unduly burdensome, in order to maintain Hong Kong’s attractiveness to IP owners and investors. In addition, alignment with overseas benchmarks on valuation thresholds and practical treatment of IP portfolios would help balance tax integrity with commercial reality.

The Chamber regards the expansion of Hong Kong’s tax treaty network as essential to bolster our standing as a preferred destination for international business operations amid the evolving global tax environment.  We are hopeful that meaningful progress can be made in the near term through active engagement with the jurisdictions as set out in the attached document.  We also understand that CDTA negotiations are ongoing with Germany and Nigeria; given the considerable market size of those two countries, we look forward to the successful conclusion of such negotiations as soon as practicable.  Accordingly, we highly recommend that the Government allocate additional resources to expedite the process.

The Chamber welcomes the opportunity to respond to the proposed revisions to the minimum and maximum levels of relevant income for MPF contributions. We recommend keeping the maximum level of relevant income unchanged at the current level of HK$30,000 in order to maintain business sustainability during this challenging period.

The Chamber supports the Government’s efforts to facilitate the digitalisation of Hong Kong’s trade documents. We believe that the digital transition of trade documents and processes will enhance certainty, efficiency, and transparency. Additionally, we encourage the Government to expedite the legislative process and provide a clear timeframe to give clarity to the industry.

The Chamber welcomes the Government’s commitment to modernising Hong Kong’s Registered Designs regime to ensure it remains competitive, aligned with global standards, and supportive of the city’s ambitions as a regional IP trading centre and international I&T hub. A strengthened, future-ready IP framework is important to fostering innovation and growth in the digital economy.

We encourage a balanced, business-friendly implementation approach grounded in international best practices and practical for local industries, helping to reduce administrative burdens and broaden participation across the design sector. We also support proposed updates to design definitions - including coverage of digital, virtual, and complex products, and the shift to assessing “product appearance”, amongst others.

The Chamber supports the Government’s proposed extension of the Virtual Asset (VA) regulatory regime to VA advisory and VA management services, which is a positive and timely development for accelerating Hong Kong’s development as a global digital asset hub. A more comprehensive framework can provide regulatory clarity for market participants while reinforcing the city's attractiveness as leading financial and innovation centre, consistent with the principle of “same activity, same risks, same regulation.”

As the regulatory regime evolves, the Chamber encourages an approach that remains responsive to market innovations, including developments such as Real-World Asset Tokenization. Additional guidance on the application of marketing related prohibitions - particularly in relation to online and cross border activities – is also recommended in supporting industry compliance. Taken together, a flexible, robust and balanced regulatory structure will be conducive to safeguarding investor interests and the continued growth of Hong Kong’s virtual asset ecosystem.