TTPS Category A HK$2.5 Million Income Assessment 2025-2026

Introduction

Since the Category A of the Top Talent Pass Scheme (TTPS) was launched on 28 December 2022, it has received over 67,000 applications, with an approval rate consistently maintained above 85%. However, in 2024 the Immigration Department noticeably tightened its income assessment for Category A — the supplementary document request rate rose by 12 percentage points year on year, and cases rejected for “income falling short of the threshold” or “income source unable to be verified” already accounted for 60% of all Category A rejections in the fourth quarter of 2024. With the first visa validity period for TTPS Category A extended from 24 months to 36 months from January 2025, and with the first batch of Category A holders facing visa extension in 2026, applicants must shift their understanding of the HK$2.5 million threshold from “roughly meeting” it to “precisely benchmarking” against it. This article breaks down item by item the assessment criteria applied by the Immigration Department to four types of income — salaries, comprehensive, overseas and equity incentive income — and provides first-hand document guidance and numerical case studies.

TTPS Category A Basic Framework: Annual Income, Taxable Nature and Supporting Documents

The statutory threshold for TTPS Category A is set out in Part 11 of Schedule 1 to the Immigration Regulations (Cap. 115A) and in the “Guidance Notes for Applicants of the Top Talent Pass Scheme” (document reference ID(C)1022) issued by the Immigration Department. Paragraph 3.1 of that guidance expressly provides that an applicant must have an annual income of HK$2.5 million or above (or its equivalent in foreign currency) in the 12 months immediately preceding the date of application (i.e. the “year of assessment” or any consecutive 12-month period). The characteristics of “income” here are threefold: first, it must be “taxable income” — that is, it must be reflected in the tax assessment documents of the tax jurisdiction to which the applicant belongs, or in an employer certificate of equivalent effect; second, it must be “realised” income — unexercised portions of options, the value of unsold shares and undistributed retained earnings are all excluded; third, there must be a clear documentary chain, forming a closed loop from the source of income, the paying institution, bank statements through to tax records. The internal assessment guidance updated by the Immigration Department in November 2024 further requires that, for cases relying solely on bank monthly statements or a self-statement letter as proof of income, if the amount exceeds HK$1 million without supporting tax documents, the processing officer may directly initiate a supplementary document procedure, with a tight deadline of only 14 working days; failure to comply by the deadline is treated as withdrawal of the application.

Salaries Income: Assessment of Fixed Employment Income and Tax Documents

Salaries income is the most straightforward category in a Category A application, yet precisely because it is “simple”, applicants easily overlook two core requirements. First, the Immigration Department requires an “Income Certificate” issued by the employer, stating the total of salary, allowances, bonuses, commissions and other cash remuneration paid within the 12 months immediately preceding the application, and signed with the employer’s authorisation. This document must be accompanied by a copy of the employer company’s Business Registration Certificate or the equivalent registration document of an overseas company, to prove the employment relationship genuinely exists. Second, the applicant must also submit the “Notice of Assessment for Salaries Tax” or the “Tax Assessment and Demand Note” issued by the Inland Revenue Department (IRD) for that year; if that year has not yet been assessed, the applicant may instead submit the “Employer’s Return of Remuneration and Pensions (IR56B Form)” completed by the employer and the applicant’s Provisional Tax Demand Note.

The key figure for practical handling in 2025–2026 is as follows: if an applicant’s annual salary reaches HK$2.7 million for the period from July 2024 to June 2025, but HK$400,000 of it is a non-guaranteed year-end bonus and the company only filed tax returns on HK$2.3 million of it, the Immigration Department will only accept HK$2.3 million. Any untaxed “verbally promised” bonus or allowance will not be included in the calculation. In addition, if the employer is an offshore company, although the income is sourced overseas, it may still be accepted provided salaries tax has been declared in Hong Kong or another tax jurisdiction; however, the applicant must additionally provide the remuneration terms stated in the employment contract and a complete 12-month bank credit record, proving that each salary payment matches the contractual terms.

Comprehensive Income: Calculation for the Self-Employed, Commission-Based Arrangements and Sole-Proprietorship Business Profits

Comprehensive income covers the self-employed (such as freelancers, consultants and those operating a business in their own name) and applicants whose principal source of income is commission. The assessment of this type of income is the most complex; the Immigration Department examines three layers of documents: tax filing records, business contracts and bank statements. According to paragraph 3.2 of the application guidance, a self-employed person must submit the “Notice of Assessment for Profits Tax” issued by the IRD and financial statements audited by a practising accountant (or a profit and loss account prepared by the applicant, together with supporting business documents); at the same time, bank account monthly statements covering the entire assessment year must be provided to corroborate that the business income was actually received.

Commission-based income from a single employer may still be handled as “salaries income”; but if the applicant provides services to multiple companies simultaneously without a fixed employment relationship, it must be declared under the “self-employed” mode. The key at this point is the “stable and sustainable” nature of the income — the Immigration Department will not automatically accept merely because there are multiple large commission payments within 12 months; rather, it will require the applicant to provide service contracts and commission records for at least the past three years, to exclude non-recurring income from one-off special transactions. In February 2025, the Immigration Department rejected a case: the applicant recorded HK$3.2 million in commissions during the reporting period, but HK$2.8 million of it came from successfully brokering a single project, with no prior history of cooperation; the Department ultimately treated that HK$2.8 million as “non-recurring capital gains” and refused the application.

If an applicant owns a company registered in Hong Kong or overseas in the form of a sole proprietorship or partnership and draws profits from the company as income, they may submit the company’s audited financial statements and the Notice of Assessment for Profits Tax, clearly showing the net profit attributable to the applicant (rather than the turnover). It must be noted that undistributed profits, reserves and share capital in the company’s accounts are not counted as personal income; only the portion that has completed profits tax filing and been actually drawn into the personal bank account meets the definition of “annual income”. In 2024, the Immigration Department amended its internal guidance, expressly requiring that the “proprietor’s remuneration” of a sole-proprietorship business must be reflected on both the company tax return (such as BIR52 Form) and the personal tax return (BIR60 Form) in order to be recognised as valid income.

Overseas Income: Reporting Requirements for Cross-Border Earnings and Currency Conversion

TTPS Category A places no geographical restriction on overseas income; in principle, any income earned and taxable outside Hong Kong within the 12 months before the application may be counted towards the HK$2.5 million total. Overseas salaries, overseas business profits and dividends from overseas investment holding companies, provided they meet the three conditions of “tax paid, credited to account and converted”, all qualify as eligible income. Specific document requirements include: a notice of assessment or tax payment certificate issued by the overseas tax authority, showing the applicant’s assessable income for that year and the tax already paid; an income certificate issued by the overseas employer or business partner, stating the total amount paid and the period; and the bank account monthly statements through which the applicant received that income, proving the cross-border inflow of funds.

On currency conversion, the Immigration Department accepts the exchange rate quoted on the date the applicant submits the application (with reference to the spot rate provided by the Hong Kong Association of Banks, or the closing rates of Bloomberg or Reuters) as the basis for converting foreign-currency income into Hong Kong dollars; where the income spans 12 months, the Department tends to convert each month’s income at that month’s end rate and then aggregate. Practical trends since 2025 show that, for a single income source in currencies with lower exchange-rate volatility (such as the US dollar, RMB and euro), the Department mostly adopts the applicant’s conversion results directly; but if the currency is a highly volatile one such as the Argentine peso or Turkish lira, it may require a currency conversion verification report issued by a third-party auditor.

It is worth noting that, where overseas income is exempted from local tax under a tax agreement (for example, certain income earned by a Hong Kong resident in Australia is exempt from Australian tax under the double taxation relief arrangement between the two places), the applicant must submit both the official approval document for that exemption and bank records proving the income’s substantive existence; otherwise the Immigration Department will find it difficult to determine the taxable nature of the income, possibly causing delay to the application.

Equity Incentives and Share Options: Timing of Inclusion, Valuation Methods and Documentary Requirements

Equity incentives (including share options, Restricted Stock Units (RSUs) and Share Appreciation Rights (SARs)) are the income source most easily overstated in a Category A application. The Immigration Department’s assessment principle is: it only accepts option gains that are “vested and exercised” within the 12 months immediately preceding the application and have been included in that year’s taxable income. In other words, options that are unvested (where the service-period or performance conditions are not yet met), even if their fair value reaches HK$3 million, may not be counted; vested but unexercised options are likewise not computed.

In practice, the applicant must submit the “Share Option Exercise Notice” or “Equity Award Settlement Statement” issued by the company, clearly stating the exercise date, number of shares exercised, exercise price and the market price on that day, so as to calculate the spread gain; in addition, this gain must already be reflected in the “Salaries Income” or “Share Option Benefits” field of the notice of assessment issued by the IRD (or the corresponding overseas tax document). Taking a Hong Kong employee as an example, the employer must report the “Share Option Gain” field in the IR56B Form, and the individual must also declare this portion of income in the BIR60 Form.

For equity incentives in unlisted companies, the difficulty is greater. Lacking an objective market price, the Immigration Department will require an equity valuation report issued by an independent valuer under the International Valuation Standards (IVS), supplemented by the term sheet of the company’s most recent funding round or its audited net asset value calculation. A typical case approved in April 2025: a senior executive at a technology company exercised options during the reporting period to obtain 2.5% equity, and, using that year’s company funding valuation, derived an equity gain of HK$2.8 million; because the valuation was supported by audited accounts and a funding agreement, the Immigration Department ultimately accepted it in full. This case reveals the key point — the value of an equity incentive must be “quantifiable, auditable and taxed”, and all three are indispensable.

Income Items That Cannot Be Counted and Three Common Misconceptions

In paragraph 3.3 of the application guidance, the Immigration Department expressly lists multiple categories of income that are not accepted, mainly including: personal investment gains (such as stock trading profits, fund dividends and bond interest), rental income from property, bank deposit interest, inheritance, gifts, lottery or gambling winnings, and income from non-taxable sources. In addition, undistributed profits held by a company controlled by the applicant, drawings under a bank credit line and policy loans are all excluded without exception.

The three most common misconceptions applicants fall into are as follows. Misconception one: treating company turnover as personal income. In a rejection case in March 2025, the applicant submitted financial statements showing the company’s annual turnover reached HK$6 million, but the net profit attributable to the individual was only HK$800,000, with the remainder being undistributed reserves; the Immigration Department expressly stated that turnover is not equivalent to income and ultimately rejected the application. Misconception two: using a one-off funds transfer in the form of a gift to pass as income. Even if the applicant submits bank records and a declaration of a gift from a relative, as long as the Department cannot establish that the funds originated from the donor’s taxable income, it classifies them as non-qualifying income. Misconception three: misinterpreting the definition of “the year immediately preceding the application”, believing one may freely choose any 12-month period within the past five years with the highest income. In reality, the Department requires that the 12-month period seamlessly connect with the application date; if the applicant submits the application on 1 October 2025, the income calculation period must be 1 October 2024 to 30 September 2025, and the full-year 2023 income records may not be used.

Latest Operational Adjustments and Practical Recommendations for 2025–2026

On 16 October 2024, the Chief Executive announced in the Policy Address that the first visa validity period for TTPS Category A would be extended from 24 months to 36 months, applicable from 1 November of the same year to all new applications and approved cases whose validity had not yet expired (see Government press release). This means that applicants in 2025–2026, once approved under TTPS Category A, will directly obtain a three-year permission to reside and work in Hong Kong, greatly enhancing the flexibility of family relocation and career planning. However, the Immigration Department also raised the financial proof requirement for Category A at the beginning of 2025 — beyond the HK$2.5 million income proof, applicants must additionally prove they hold no less than HK$500,000 in liquid assets (such as cash deposits, stocks and funds) to ensure their initial living in Hong Kong is without worry; although this is not part of the income assessment, it has become a necessary condition for Category A approval.

Regarding the assessment of the various types of income above, three practical recommendations are crucial. First, before applying, be sure to complete the tax filing for the relevant year and obtain the official assessment documents; do not submit the application relying only on an employer letter or bank records, otherwise there is a very high chance of triggering a supplementary document request or rejection. Second, all non-Hong-Kong-dollar income should retain conversion records and screenshots of the exchange-rate source; where highly volatile currencies are involved, a third-party verification report should be submitted proactively. Third, where equity incentives are involved, communicate in advance with the company’s human resources and tax departments to confirm that the option exercise gains have been correctly reported in the tax return, and seek to obtain a certified summary of equity gains, to avoid delay caused by lagging tax filing.

Conclusion

The HK$2.5 million threshold of TTPS Category A appears on the surface to be a single figure, yet behind it lies a composite verification system combining taxation, employment, accounting and valuation. For 2025–2026, as the first visa period is extended and scrutiny intensifies, rather than trying to “get through” by estimation, applicants would do better to use a rigorously structured document checklist to benchmark against the Immigration Department’s four assessment categories one by one. Once, before submission, the four evidence chains — salaries tax assessment, comprehensive profits report, overseas tax documents and equity exercise records — are fully closed, the certainty of approval will rise significantly.

This article is for informational reference only and does not constitute legal advice. For professional legal or tax advice on your individual circumstances, please consult a practising solicitor or accountant in Hong Kong.