On 6 November 2026, the Under Secretary for Financial Services and the Treasury briefed the Legislative Council Panel on Financial Affairs on a 2026-27 Budget legislative proposal to relieve stamp duty on transfers of non-residential property for REITs preparing to list in Hong Kong. This note summarises the public GIA / IRD archive — general information only, not legal or tax advice. It is a legislative proposal, not yet law. Final wording, commencement and any refund mechanics will follow the Bill and enacted text.
Key point: The Government aims to introduce the Bill in the first half of 2027. Relief is proposed to run from the day the Bill is introduced; stamp duty paid in the interim would be refundable after passage if all conditions are met. Transfers of residential property are not covered.
Who and what the proposal would cover
- New REITs preparing to list in Hong Kong, including overseas-listed REITs seeking dual primary or secondary listing in Hong Kong.
- The REIT must list on the Stock Exchange of Hong Kong within six months after the property transfer.
- Both direct transfers of non-residential property and transfers of shares in a special purpose vehicle (SPV) holding such property would be in scope.
- Residential property transfers would not qualify.
Proposed anti-abuse conditions
- Hold the property or SPV shares for at least two years.
- Maintain the REIT listing for at least two years.
- Details await the Bill; do not assume the exemption is already in force or immediately claimable.
How this differs from intra-group stamp duty relief
Readers often ask whether this is a general SME / holding-company property relief. It is not. The proposal is specific to pre-listing REITs and non-residential property (or related SPV share) transfers. It is a different mechanism from stamp duty relief between associated bodies corporate. See our note on the proposed intra-group stamp duty relief threshold change. Ordinary intra-group property or share reorganisations should still follow the current Stamp Duty Ordinance and related relief rules, with professional advice.
Related measures and timetable (public sources)
- Unit transfers — stamp duty on REIT unit transfers has been exempt since December 2024 (per official public materials).
- The IRD Budget tax-measures page also notes this item (around measure (vii)) as still pending legislation.
- The same briefing mentioned a separate SFO amendment Bill, targeted around 11 November 2026, on REIT restructuring and mandatory acquisition — a distinct agenda item, not detailed here.
- Stock Connect inclusion of REITs is separate ongoing work from this stamp duty proposal.
Company secretarial / holding-structure tips
- Groups assessing SPV-held non-residential property and a REIT listing path should plan holding periods, listing timetable and anti-abuse conditions alongside company-secretarial and share documents.
- Until the Bill is introduced and enacted, transfers remain taxable under current stamp duty rules; any refund depends on the future Ordinance.
- Do not read this proposal as general SME property-transfer relief.
Sources: GIA: FSTB US opening remarks (ZH, 2026-11-06) · IRD press archive (ZH) · IRD: Budget tax measures
Related services: Hong Kong profits tax · Annual return / company secretary · Hong Kong company incorporation · BVI / offshore incorporation · Accounting