Hong Kong Property: Implications of China’s taxation on offshore trusts

Research evidence excerpt

Hong Kong Property: Implications of China’s taxation on offshore trusts

J P M O R G A N Asia Pacific Equity Research

27 July 2026

Hong Kong Property

Implications of China’s taxation on offshore trusts

China’s latest taxation on offshore trusts (20% tax rate) is not a major surprise, Mainland China/Hong Kong Property

given Bloomberg’s late-March report (link). However, the new framework appears & Conglomerates

stricter than expected, featuring retroactive provisions (e.g., income from 2023 Karl Chan AC

must be declared within 90 days) and enhanced anti-avoidance measures (e.g., (852) 2800-8513

obtaining foreign citizenship alone may not eliminate tax obligations). While the karl.chan@jpmorgan.com

move is not specifically aimed at Mainland Chinese purchases of HK property, it Venus Choi

still reduces the financial attractiveness of holding Hong Kong real estate—and, (852) 2800-8599

more broadly, offshore assets—thereby we consider it directionally negative for venus.choi@jpmorgan.com

J.P. Morgan Securities (Asia Pacific) Limited/ J.P.

HK property. That said, we believe the impact is manageable, as we estimate Morgan Broking (Hong Kong) Limited

<2% of property sales are purchased via entities under Mainland Chinese-

controlled offshore trusts, so this change alone is unlikely to derail the current

upcycle in home prices (although we believe the growth momentum will still slow

down in 2H26, regardless of this taxation – more in our earlier report). Arguably,

this may also mildly slow down the sales momentum among en-bloc commercial

properties and thus drag the pace of property companies’ capital recycling. In the

near term, the concerns on capital outflow control and rate hike remain two

overhangs for the HK residential market, and thus we generally prefer landlords