Mr. Zhang from Shenzhen obtained Hong Kong residency in 2024 through the High-Talent Pass (Category A). He holds shares in a company with the stock code 60%, which has an annual revenue of 3 million RMB, theoretically meeting the Category A annual salary threshold of 2.5 million RMB.

He thought he was in the clear, but when he applied for renewal in May 2026, the Immigration Department asked him to submit additional documents—the tax payment certificate from the tax authority didn’t match the company’s profits.

The main reason is“Shareholding Percentage” and ”Tax Payment Method”Two details weren't handled correctly.

01

Core Criteria for Class A Designation

There are three core rules for the eligibility criteria of the Gaocaitong Category A program in 2026:

First, 2.5 million Hong Kong dollars = the actual taxable income for the previous full tax year.It’s not corporate profits, not revenue, and not dividend forecasts—it’s the ”tax-paid income” reflected in the “Individual + Income Tax” app.

Second, the ownership percentage is ≥ 50%.This restriction took effect in December 2025; previously, holding ≥ 30% was sufficient. General Manager Zhang’s 60% is fine, but many business owners holding 40% have had their applications rejected.

Third, the method of tax payment must be through wages or dividends.Consulting fees, service fees, and bonuses must be individually matched to tax payment records. Dividends from Cayman Islands or BVI companies under a VIE structure must be verified based on actual receipts.

These three requirements are mandatory criteria for 2026, and none can be omitted.

02

Three Details About General Manager Zhang's Rejection

First detail: The timing of the shareholding percentage.At the time of application, Mr. Zhang held 60% shares, but the Immigration Department reviewed his shareholding for the ”previous full tax year”—in the 2024 tax year, he transferred 5% shares to his wife, resulting in a shareholding of only 55% for that year.

Although the number of TP3T shares was still ≥501, he failed to submit documentation regarding the change in equity ownership and was deemed to have ”incomplete materials.”

Second detail: Choosing a tax payment method.His company made a profit of 3 million, which he distributed to himself as a combination of ”salary and dividends.” Of this amount, 1 million was recorded as salary for tax purposes, and the 2 million in dividends was also reported; however, the dividends were taxed under the ”20% tax rate”—meaning such large dividends are classified as ”non-labor income.”

The Immigration Department required him to provide proof of ”actual job responsibilities,” such as a breakdown of his job duties corresponding to his salary, social security contributions, and personal income tax returns.

Third Detail: Determination of the Taxable Year.Mr. Zhang received his High-Talent Pass in December 2024, but his actual income for the 2024 tax year came from the company’s profit distribution in 2023. The Immigration Department determined that the ”tax year 2023” corresponds to the company’s ”fiscal year 2022.” As a result, the company’s fiscal year and the individual income tax year do not align.

📌 These three details are all ”minor issues,” but the Immigration Department’s strict compliance requirements for Category A visa renewals in 2026 have turned these ”minor issues” into ”major problems.”

03

Four Steps to Prepare for the 2026 Category A Exam

Step 1: Stabilize the equity structure one year in advance.Do not transfer any equity shares during the 12 months prior to applying. Equity held by a spouse, relative, or trust is not permitted; you must hold the shares directly in your own name.

Step 2: The primary method of tax payment is through payroll.Of the 2.5 million in taxable income, at least 60% was received as wages (1.2 million), and the remaining 40% (1 million) was received as dividends or bonuses. Thus, the Immigration Department views this as ”employment income.”

Step 3: Ensure full compliance with job responsibilities and social security requirements.Before submitting your application in Hong Kong, ensure that your mainland social security records, personal income tax app records, and pay stubs are all matched up one-to-one to prove that ”your salary is genuine income from employment.”

Step 4: Align the company's fiscal year with the individual's tax year.If the company’s fiscal year runs from April to March, an ”annual adjustment” must be made in advance to ensure that the tax payment data for the application year reflects actual figures for a full fiscal year.

It took Mr. Zhang two months and 20,000 in attorney fees to submit the additional documents this time. If he had followed these four steps from the start, he would have easily secured his renewal within six months.

For Class A, it’s not a matter of ”having money is enough to pass”; it’s about ”having the right structure to pass.”

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