List of Debt Instruments and Sovereign Bonds Eligible for Profits Tax Concession or Exemption (as at the end of 31 December 2025)

(The following lists are compiled based on the information provided by the issuers.)

Qualifying Debt Instrument Scheme

• Qualifying Debt Instruments issued before 1 April 2018
  • Short Term/ Medium Term Debt Instruments Eligible for Profits Tax Concession
    The short term/ medium term debt instruments are intended to be eligible for profits tax concession (i.e. chargeable at 50% of the normal profits tax rate) in accordance with section 14A(1) of the Inland Revenue Ordinance (IRO).
  • Long Term Debt Instruments Eligible for Profits Tax Exemption
    The long term debt instruments are intended to be eligible for profits tax exemption in accordance with section 26A(1) of the IRO as from the year of assessment 2003/04.
• Qualifying Debt Instruments issued on or after 1 April 2018
  The debt instruments are intended to be eligible for profits tax exemption in accordance with section 14A(1B) of the IRO as from the year of assessment 2018/19.

Renminbi and Non-Renminbi Sovereign Bonds

With effect from the year of assessment 2009/10, sums received by, or accrued to, any person as interest paid or payable on, and profits derived from the sale, disposal or redemption upon maturity or presentment of, sovereign bonds denominated in the Renminbi and issued in Hong Kong by the Central People’s Government (CPG) are exempt from profits tax pursuant to the Exemption from Profits Tax (Renminbi Sovereign Bonds) Order (Cap. 112BH).  Commencing from the year of assessment 2017/18, this exemption was extended to cover non-Renminbi sovereign bonds issued in Hong Kong by the CPG pursuant to the Exemption from Profits Tax (Non-Renminbi Sovereign Bonds) Order (Cap. 112DA).

People’s Bank of China Debt Instruments

With effect from the year of assessment 2018/19, sums received by, or accrued to, any person as interest paid or payable on, and profits derived from the sale, disposal or redemption upon maturity or presentment of, debt instruments issued in Hong Kong by the People’s Bank of China are exempt from profits tax pursuant to the Exemption from Profits Tax (People’s Bank of China Debt Instrument) Order (Cap. 112DF).

Debt Instruments Issued By Mainland Local People’s Government at Any Level

Sums received by, or accrued to, any person as interest paid or payable on, and profits derived from the sale, disposal or redemption upon maturity or presentment of, debt instruments issued in Hong Kong by the Shenzhen Municipal People’s Government were exempt from profits tax with effect from the year of assessment 2021/22 pursuant to the now-repealed Exemption from Profits Tax (Shenzhen Municipal People’s Government Debt Instrument) Order (Cap. 112DP).  On 31 March 2023, Cap. 112DP was repealed and the Exemption from Profits Tax (Debt Instrument Issued by Mainland Local People’s Government at Any Level) Order (Cap. 112DR) commenced to take effect.  Under Cap. 112DR, sums received by, or accrued to, any person as interest paid or payable on, and profits derived from the sale, disposal or redemption upon maturity or presentment of, debt instruments issued in Hong Kong by a local people’s government at any level in Chinese Mainland are exempt from profits tax with effect from the year of assessment 2022/23.