AXA Hong Kong unit re-domiciles from Bermuda to Hong Kong

Move aligns structure with Greater China base, Macau renaming planned

AXA Hong Kong unit re-domiciles from Bermuda to Hong Kong

Insurance News

By Roxanne Libatique

AXA Hong Kong and Macau has shifted its place of incorporation from Bermuda to Hong Kong under the Hong Kong Special Administrative Region Government’s company re-domiciliation regime, and is now operating as AXA China Region Insurance Company (Hong Kong) Limited with effect from Jan. 26. The change follows Manulife (International) Limited’s re-domiciliation in December 2025 and adds another international insurance group to the list of firms using the mechanism to relocate their legal domicile to Hong Kong while maintaining ongoing operations.

AXA explains rationale for change of domicile

According to AXA Hong Kong and Macau, the decision is intended to bring the group’s legal structure into line with its operational base in Greater China and its existing business in the Hong Kong market. Sally Wan, chief executive officer, AXA Greater China, said the move reflects the group’s assessment of Hong Kong’s role in its regional strategy. “The re-domiciliation underscores our strong confidence in Hong Kong’s strategic importance and growth potential, and reflects our unwavering commitment to serving customers with resilience and innovation. Leveraging Hong Kong’s robust economy and its role as a regional hub for insurance and risk management, we are confident that AXA’s long-term success will continue to advance. Looking ahead, we remain committed to creating long-term value for our customers, partners, and the community, while actively pursuing sustainable growth,” Wan said. AXA said that, following the change of domicile, it plans to apply to the relevant authorities in Macau in the week commencing Feb. 2 to update the name of its Macau branch so that it corresponds to the Hong Kong-incorporated entity. AXA Hong Kong and Macau is part of the AXA Group and provides life, health, and general insurance, as well as employee benefits solutions, to customers in Hong Kong and Macau.

Insurance Authority positions regime as part of headquarters strategy

The Insurance Authority (IA) has framed AXA’s move in the context of the government’s policy to attract corporate headquarters and regional platforms to Hong Kong. In a response to media enquiries on the re-domiciliation, the IA said it “welcomes the re-domiciliation of AXA to Hong Kong under the company re-domiciliation regime. The addition of a re-domiciled insurer reinforces Hong Kong’s strong appeal as an international financial centre and the industry’s commitment to contributing to Hong Kong as a regional insurance hub.”

The regulator also stated that it “will continue to work closely with all relevant parties to enable interested insurers to re-domicile to Hong Kong under the regime, supporting the government’s vision to strengthen headquarters economy.” Taken together, the statements indicate that the IA views insurer re-domiciliations as aligned with broader policy to consolidate regional management, risk oversight, and capital functions in Hong Kong. 

Manulife’s December 2025 move was first under the regime

AXA’s re-domiciliation comes after Manulife (International) Limited completed its transfer of domicile from Bermuda to Hong Kong on Dec. 12, 2025, becoming the first insurer to finalise the process under the new regime. At the time, Manulife said the move was intended to localise its legal domicile in line with its Hong Kong and Macau operations and to support its longer-term business plans in the region. “This move reflects our deep-rooted belief in Hong Kong’s future and its importance to our business. Re-domiciling locally strengthens our alignment with Hong Kong’s robust regulatory framework and enables us to better serve our 2.6 million customers in both Hong Kong and Macao, advancing our ambition to be the number one choice for customers,” Patrick Graham, chief executive officer of Manulife Hong Kong and Macau, said when the change was announced. For insurers with long-standing Hong Kong and Macau franchises booked through offshore entities, Manulife’s and AXA’s transactions provide early examples of how the regime can be used to move domicile onshore while keeping continuity of policies, contracts, and corporate identity. 

Framework and tax treatment under Hong Kong law

The company re-domiciliation regime is based on amendments introduced through the Companies (Amendment) (No. 2) Bill 2024, which was passed in 2025 and later gazetted as the Companies (Amendment) (No. 2) Ordinance 2025. The amendments allow non-Hong Kong-incorporated companies to register as re-domiciled entities under the Companies Ordinance (Cap. 622), preserving legal identity and ongoing business relationships instead of winding up and re-incorporating. When the bill was passed in May 2025, IA chief executive officer Clement Cheung described the response from insurers with existing Hong Kong operations. “The Amendment Bill is eagerly awaited by authorized insurers incorporated outside Hong Kong but with a prominent local presence. Their choice of Hong Kong as home base fully reflects the strengths and allure of our market driven by connectivity among cities in the Guangdong-Hong Kong-Macao Greater Bay Area,” Cheung said.

Related changes were made to the Inland Revenue Ordinance (Cap. 112). Hong Kong applies a territorial system of taxation, under which profits tax is charged on profits arising in or derived from Hong Kong from a trade, profession, or business, excluding gains on capital assets. Re-domiciliation does not remove profits tax liabilities on Hong Kong-source profits earned before the move for companies that were already carrying on business in the territory. By contrast, where a company has not conducted trade, a profession or business in Hong Kong before re-domiciling, no Hong Kong profits tax is assessed for the pre-domiciliation period. 

Considerations for Asian insurance groups

For insurers operating across Asia, the Hong Kong regime offers a regulatory route to bring group legal domicile closer to regional management centres without interrupting existing contracts or policyholder relationships. Manulife and AXA, both with extensive operations in Hong Kong and Macau and legacy Bermudian entities, have now used the framework to re-domicile to Hong Kong. Market observers in the insurance sector are watching whether additional life and general insurers with significant Hong Kong or Greater Bay Area portfolios decide to follow, using the regime to place their legal domicile under Hong Kong company law and supervision while continuing day-to-day operations in the region.

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