For international companies looking south into China, the Guangdong-Hong Kong-Macao Greater Bay Area has become one of the more practical places to expand. The region brings together Hong Kong, Macao and nine cities in Guangdong province - Guangzhou, Shenzhen, Zhuhai, Foshan, Huizhou, Dongguan, Zhongshan, Jiangmen and Zhaoqing - across roughly 56,000 square kilometres. Its combined population is more than 88 million, and regional GDP passed RMB 15 trillion in 2025. That places a single, increasingly integrated market on Hong Kong's doorstep.
Since the Outline Development Plan was promulgated in February 2019, policy has pushed steadily towards closer integration of talent, capital and goods across the eleven cities. Physical connections have followed. The Hong Kong-Zhuhai-Macao Bridge and the Guangzhou-Shenzhen-Hong Kong Express Rail Link now put Shenzhen within around 20 minutes of West Kowloon and Guangzhou within the hour. For a business, the appeal of the region is well established. What takes more thought is how to structure for it.
Why structure comes first
The Greater Bay Area spans two legal systems, two currencies and several tax regimes. Hong Kong runs on common law with a territorial tax system. The mainland cities operate under PRC law, with their own company, tax and foreign-exchange rules. A structure suited to a mainland trading operation will not necessarily suit a regional holding company, and choices made for speed at the start can be costly to unwind later.
Three things tend to depend on the structure chosen: how profits are taxed and moved within the group, how capital and people cross borders, and how each entity meets its compliance obligations locally. These are planning questions, and they are easier to settle before incorporation than after.
Hong Kong's role
Hong Kong continues to serve as the working entry point to the region, for reasons that are familiar but still hold. It operates under common law, with an independent judiciary and a regulatory environment that international businesses and their banks understand. Capital moves freely. The professional services base is deep. The International Institute for Management Development ranked Hong Kong the third most competitive economy in the world in 2025, and the World Trade Organization placed it as the seventh largest trading entity in 2024.
The tax framework is a large part of the case. Hong Kong taxes profits on a territorial basis, so tax generally applies only to profits arising in or derived from Hong Kong. Under the two-tiered regime, profits tax is charged at 8.25% on the first HK$2 million of assessable profits and 16.5% on the balance. Hong Kong also maintains a wide network of double taxation agreements, which can matter when income flows between entities in different jurisdictions. For many groups, the practical outcome is a Hong Kong holding or management company sitting above operating entities elsewhere in the region.
A newer route: re-domiciliation
Companies that already hold their regional structure through an offshore vehicle have an additional option. Since 23 May 2025, Hong Kong's inward re-domiciliation regime, introduced under Part 17A of the Companies Ordinance, has allowed an eligible non-Hong Kong company to move its place of incorporation to Hong Kong while keeping the same legal identity. Contracts, assets and banking relationships carry across, and there is no economic substance test of the kind some other jurisdictions impose.
A few features are worth keeping in mind. The regime is inward only. A re-domiciled company must deregister in its original jurisdiction within 120 days of the move. And while re-domiciliation does not in itself trigger a Hong Kong profits tax charge, the tax position will depend on the company's own circumstances, including any business carried on in Hong Kong before the move. This is one area where advice should be taken before an application is made.
Putting it into practice
For a company weighing a Greater Bay Area strategy, the early work usually falls into a handful of areas: selecting the holding structure, incorporating and administering the Hong Kong entity, putting accounting, tax and corporate secretarial arrangements in place, and keeping each entity compliant as the business grows.
Alpadis supports international companies across this work from its Hong Kong office. The team handles company formation, corporate secretarial services, accounting, tax compliance and ongoing regulatory compliance. For families and business owners holding assets across the region, the Hong Kong office also provides trust and fiduciary structuring. As an independent firm, with no ties to banks or law firms, Alpadis is able to coordinate these services across its offices in Asia, the Middle East and Europe, which helps where a Greater Bay Area structure connects to interests in other markets.
Hong Kong's position in the region rests on more than proximity to a large market. It offers a familiar legal system, an established professional infrastructure and a tax framework built for international business. For most companies entering the Greater Bay Area, that combination makes it the sensible place to begin.
