The Hong Kong Comeback Story: Family Office Numbers vs Reality (End-2025 Counts)

Originally published: 2025-04 | Last verified: 2026-09-12 Counts are linked inline to the InvestHK announcement (February 2026), the Legislative Council written reply (July 2025), and the MAS parliamentary reply (August 2026) they come from. Both headline counts are struck at end-2025; the gap between them is about what each one counts. An earlier version of this piece estimated Hong Kong’s like-for-like lead at 5-15% and charted an 800-office “FIHV-comparable” figure; neither had a source, and both have been removed. Family office counts vary by methodology; the cited HK and SG numbers reflect the official InvestHK and MAS-linked figures respectively.

For most of 2022 through early 2024, the conventional read on Hong Kong’s family office picture was a quiet retreat. The story most often told was of capital leaving Hong Kong for Singapore. The narrative framing was: Hong Kong was structurally losing the regional family office competition, Singapore was structurally winning, and the next ten years would see the gap widen.

The 2025 numbers tell a different story, or at least they appear to. InvestHK and Deloitte’s joint Market Study put the Hong Kong single-family office count at over 3,380 as at the end of 2025, an increase of about 680 offices in two years — ahead, on the headline numbers, of the more than 2,000 single family offices that MAS says were receiving Singapore’s tax incentives at end-December 2025. The dedicated FamilyOfficeHK team within InvestHK assisted 50 family offices to set up or expand in Hong Kong in the first five months of 2025, a 19% year-over-year increase. The headline narrative shifted from “Hong Kong is losing” to “Hong Kong has come back.”

One comparison caveat before going further, because it cuts against the headline. Both numbers are end-2025 counts, so the gap is not a calendar artifact. But MAS publishes only a floor — “more than 2,000” — not a point figure. On the headline numbers, Hong Kong’s lead is therefore at most about 69% (3,380 against 2,000), and smaller by however far Singapore’s true count sits above 2,000. The larger problem is that the two numbers count different things, which is what this piece is about.

The shift in headline numbers is real. Whether it represents a structural recovery in Hong Kong’s family office competitive position — or whether it reflects a combination of methodology differences, base-rate effects, and a more aggressive promotional push — is a different question. The practitioner read I’d offer is that all three factors are at work, and the comeback narrative is partly real, partly definitional, and partly contingent on factors that could shift again.

What the numbers actually count

The first thing to surface is that the Hong Kong 3,380 and the Singapore 2,000+ figures are not measuring the same thing.

The Hong Kong figure comes from a market study commissioned by InvestHK and conducted by Deloitte, which estimates the number of single-family offices operating in Hong Kong. The announcement does not set out the counting method in detail, but it is a count of offices operating in the city, not of offices holding any particular tax concession.

The Singapore 2,000+ figure is MAS’s count of single-family offices receiving tax incentives under sections 13O and 13U of the Income Tax Act. This is a narrow count that captures only those structures that have applied for and received an incentive.

The two numbers are therefore comparing populations defined differently. The genuine apples-to-apples comparison, if we wanted to make one, would require either:

• Adjusting the Singapore figure upward to capture the family offices that operate in Singapore without applying for 13O or 13U. Nobody publishes that number. MAS’s revised single family office framework, in force since 15 June 2026, requires qualifying SFOs to notify MAS and file a simple annual return, which MAS says will enhance its monitoring of SFOs; it has not said whether it will publish a count.
• Adjusting the Hong Kong figure downward to capture only those structures that have applied for the equivalent Hong Kong tax-incentive scheme (the 2023 Family-Owned Investment Holding Vehicle tax concession). The government has not published that number either: in a Legislative Council written reply in July 2025, it said “a relatively small number” of FIHV concession applications had been received for the 2022/23 and 2023/24 years of assessment, and that “it may not be appropriate to disclose relevant data.”

Neither adjustment can be made from published data, and the headline coverage makes neither. So the honest conclusion is narrower than a scorecard: the headline comparison overstates Hong Kong’s like-for-like position by an amount nobody can measure, the roughly 69% figure is an upper bound on even the headline lead, and on a like-for-like basis the direction of the gap cannot be established. Hong Kong may be ahead; it may not be.

The Hong Kong number is correct as a measure of family offices that exist in Hong Kong. The Singapore number is correct as a measure of family offices that have applied for the 13O or 13U incentive. Comparing them directly is comparing a population to a permit count.— Hong Kong-based wealth lawyer, family office practice

What’s actually pulling family offices back to Hong Kong

Whatever the like-for-like count, the direction of travel is positive: the InvestHK study counts about 680 more offices than two years earlier, and FamilyOfficeHK’s assisted set-ups were up 19% year on year in early 2025. Three structural drivers behind the renewed Hong Kong attractiveness, ordered roughly by their weight in practitioner conversations.

Driver 1: Mainland China proximity and the policy backstop. For wealth holders with significant continuing exposure to mainland Chinese operating businesses, mainland investment portfolios, or mainland family relationships, Hong Kong’s proximity (geographically, regulatorily, and culturally) is structurally hard to substitute. The post-2023 mainland economic re-engagement narrative — even with all its caveats — restored some confidence that Hong Kong’s role as China’s offshore financial hub remains policy-supported through the central government. For wealth holders whose portfolios make Hong Kong’s proximity an asset rather than a risk, the case for Hong Kong has strengthened.

Driver 2: The 2023 tax incentive scheme and supporting infrastructure. Hong Kong’s Family-Owned Investment Holding Vehicle (FIHV) regime, introduced in 2023, plus the dedicated FamilyOfficeHK team, plus a series of supporting policy initiatives (talent attraction visas, supporting service-provider tax incentives, art-storage and luxury-asset infrastructure), have together built a competitive framework that Hong Kong did not have during the 2020-2022 period. On paper the framework is now competitive, particularly for families whose portfolio profile fits the Hong Kong infrastructure — even if take-up of the FIHV concession itself has so far been small.

Driver 3: Singapore’s friction has risen. The other half of the rebalancing story is that Singapore has become harder to access. The post-2023 substance updates (Section 13O/13U tightening), the AML/CFT enhancement cycle (covered in detail in our post on the 2024-2025 MAS AML/CFT tightening), the lengthening bank account opening timelines, and the rising compensation cost for Investment Professional hires have together meaningfully raised the all-in cost and time of Singapore family office setup. Some of the wealth that would historically have defaulted to Singapore is now genuinely undecided between SG and HK, and Hong Kong’s softer friction has become a real differentiator.

What the comeback does not undo

Three things that the headline number does not change about the underlying competitive position.

The political-stability discount. For wealth holders whose primary motivation for choosing an Asian wealth hub is political-stability optionality — diversification away from any single sovereign exposure — Singapore continues to carry a meaningful premium over Hong Kong. The 2020-2022 period left a durable risk-perception gap that has narrowed but not closed. For non-China-adjacent wealth, particularly Indian, Indonesian, broader-Asian, and increasingly Latin American wealth, Singapore remains the stability default. The comeback in Hong Kong is concentrated in China-adjacent wealth flows — BCG attributes Hong Kong’s 2025 booking-centre growth to mainland China inflows, IPO activity, and equity-market gains — one strand of the broader China and India wealth outflow to Asia — not in the broader cross-Asian allocation.

The infrastructure depth. Singapore’s accumulated infrastructure depth across fund administration, multi-family office services, legal counsel specialization, and ancillary services (tax advisory, art and collectibles services, executive search) remains, on practitioner consensus, ahead of Hong Kong’s. This is not a quality-of-individual-practitioner statement — both jurisdictions have excellent practitioners — but a depth-of-bench statement. For any non-trivial structuring problem, the Singapore market has more parallel sources of expertise.

The substance regime maturity. Singapore’s Section 13O/13U framework, despite the post-2023 tightening, is significantly more mature and predictable than Hong Kong’s FIHV regime. Practitioners and clients have a considerably longer operating record with the Singapore incentives than with Hong Kong’s FIHV concession, which dates from 2023. This maturity affects everything from advisory pricing to litigation risk to the speed of regulatory clarification.

How to read the comeback

For a wealth holder evaluating Hong Kong vs Singapore in 2026, the right framework is not “Hong Kong has won, choose Hong Kong” or “Singapore is still the answer, ignore the noise.” The right framework is: which of the three structural drivers above apply to your specific profile, and which of the three things-the-comeback-does-not-undo are deal-breakers for you.

A simplified decision overlay:

The practitioner read I keep coming back to: the Hong Kong comeback is real for the China-adjacent wealth segment and for the friction-sensitive mid-tier. It is not a comeback for the broader Asian wealth hub competition, where Singapore continues to hold structural advantages.

What might shift in the next 18 months

Three things to watch.

Singapore’s revised SFO licensing framework. MAS’s revised framework took effect on 15 June 2026: a structure-agnostic class exemption from licensing, under which qualifying SFOs need only notify MAS, keep an account with a MAS-licensed bank, and file a straightforward annual return, with existing SFOs given until 15 June 2027 to comply. If it works in practice as a simpler route in, it narrows the friction differential that has driven some flow to Hong Kong, and the friction-driven portion of the Hong Kong inflow could reverse.

Hong Kong’s continued political-environment trajectory. The political-stability discount that affects non-China-adjacent wealth flow into Hong Kong is contingent on continued political environment trajectory. Any escalation of US-China tension or any specific Hong Kong governance event could re-widen the discount and reverse some of the 2025 inflow.

The China onshore wealth picture. If mainland China’s domestic wealth-management infrastructure deepens enough that Chinese UHNW holders are increasingly comfortable keeping wealth onshore rather than booking it through Hong Kong, the China-adjacent driver of Hong Kong’s comeback weakens. This is a slow shift but the directional pressure exists.

The clean summary: Hong Kong is back, but not in the way the headline numbers suggest. The 3,380 vs 2,000-plus comparison sets only an upper bound of about 69% on Hong Kong’s lead, published data cannot say which city is ahead like-for-like, the structural drivers behind the rebalancing are specific and identifiable, and the comeback is contingent on factors that could shift again. Practitioners and clients who treat the headline as the full story will end up making setup decisions based on the wrong framework.