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The question asked actually belies a bigger issue when it comes to getting a  business investment visa for Hong Kong…

PRACTICE UPDATE: How the content must now be read in light of current ImmD policy:

Historically, this Question of the Week addressed a classic structuring query from an international services or cross-border trade entrepreneur: could an applicant secure an Investment as Entrepreneur visa if all the underlying commercial work, project execution, or operational delivery took place outside Hong Kong? The Geeza’s advice reflected the classic, flexible doctrine of Hong Kong as a regional treasury, holding company, and command-and-control hub. In that era, ImmD was receptive to cross-border narratives: as long as the applicant established that the Hong Kong entity was the genuine administrative, contractual, and banking nerve center—invoicing international clients, receiving payments, managing regional suppliers, and remitting profits through the territory—the absence of physical on-the-ground client work in Hong Kong was not fatal. Under the prevailing discretionary regime, an articulate founder could win approval with modest seed capital of a few hundred thousand dollars, a flexible desk in a serviced office or co-working space to handle local administration, and a forward-looking plan to hire local administrative support over a two- to three-year ramp-up period.

The game has changed from an accommodating regional hub narrative into an uncompromising, onshore operational audit. The historical concept of running an offshore-focused consultancy or trading vehicle through a lean Hong Kong nerve center is now an administrative death trap for visa applicants. Under post-April 2026 administrative practice aligned with TTPS Category A operational substance (~HKD 2.5M enterprise scale), ImmD does not evaluate offshore revenue generation through qualitative justifications or high-level holding structures. If an un-incubated company conducts its actual business outside Hong Kong, case officers view it with immediate skepticism as an offshore shell or paper vehicle designed merely to buy residency. To satisfy the statutory “substantial contribution” test today, ImmD requires non-negotiable, verifiable domestic corporate hardware audited on day one: HKD 1.5M–2.0M in deployed corporate bank liquidity sitting in a local bank account, an executed commercial lease for exclusive physical premises (“four walls”) that strictly disqualifies serviced offices, virtual addresses, and co-working desks entirely, and active Mandatory Provident Fund (MPF) payroll contributions for 2–3 local Hong Kong permanent residents working directly on-site.

Consequently, claiming that all substantive work is undertaken outside the territory now actively undermines an independent entrepreneur application. If the work is performed abroad, ImmD will question why local staff are needed, why expensive physical four-walls premises are justified, and whether the enterprise generates genuine local economic integration. Without enterprise-grade local infrastructure and immediate local headcount, the application faces swift and summary refusal. The only viable path for cross-border or foreign-focused ventures seeking early-stage entry without heavy domestic overhead is formal, documented admission into an officially accredited government incubator (such as Cyberport, HKSTP, or the Design Incubation Programme)—which acts as the sole statutory mechanism to waive the mandatory day-one local liquidity, dedicated commercial lease, and immediate MPF headcount thresholds. Outside this accredited institutional safe harbor, attempting to secure an entrepreneur visa for an externally focused venture on historical nerve-center arguments will result in immediate refusal.

QUESTION  OF  THE  WEEK

I’m looking at incorporating an internet based Company in Hong Kong, with the intention to cut my residency ties to my current country and operate the Company full time there.

All of the income generated would be from outside of Hong Kong.

My question is, under the business investment Vvsa, how many days per year would I need to be in Hong Kong in order to maintain my investment visa at the end of each year?

Thanks in advance for your reply.

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