Past Seminars / Events
Programme Code : 20190425
Event Date : 25 April 2019 (Thursday)
Time : 6 : 45 pm-8 : 45 pm (6 : 15 pm registration)
Venue : Room UR8, SCOPE, 8/F, United Centre, Admiralty, Hong Kong View google map
Speakers : Mr Roy Phan, Director, Tax & Business Advisory Services, International Tax, Deloitte China
Language : Cantonese
CPD Credit : 2 hrs
Proficiency Level : Intermediate Level
Fee : HK $ 250 for TIHK member / student
HK $ 350 for Non-member
HK $ 300 for members of organizations of CPD Alliance

The offshore fund tax exemption regime has existed in Hong Kong for over a decade and it was subsequently amended in 2015 to extend the tax exemption to offshore PE funds that do not invest into Hong Kong private companies.


Recently, the Inland Revenue (Profits Tax Exemption for Funds) (Amendment) Bill 2018 (Bill) was passed, which has completely changed the landscape of the tax exemption for funds.  The Bill seeks to unify the Hong Kong tax exemption regimes for privately-offered funds. It is proposed under the Bill that the scope of tax exemption would be further extended to cover all "funds" (regardless of the type, size, location of central management and control, etc.), provided the requisite conditions are satisfied.  The new unified fund exemption regime will come into operation on 1 April 2019.


The Bill is welcomed by the fund industry in general, as it helps addressing EU's concerns against Hong Kong's existing offshore fund exemption regime as containing "ring-fencing" features, and also further consolidates Hong Kong's competitive edge in the asset and wealth management industry by relaxing the tax exemption rules for "funds" and allowing funds that invest in Hong Kong private companies to be eligible for tax exemption provided certain conditions are met. In this seminar, we will help you to understand the main changes and the potential implications of the Bill. We’ll discuss:


1. The existing exemption regime and the background for the proposed amendment

2. Key features of the Bill

3. Our key observations on the Bill's potential implications to different types of funds (such as hedge funds, PE funds, VC funds, RE funds, etc)

4. Other considerations (e.g. operational aspects, tax implications of carried interest and/ or management fee, etc.)

Speaker Profile Content :
Mr Roy Phan, Director
Tax & Business Advisory Services, International Tax
Deloitte China

Roy is a tax director based in Hong Kong. He has more than 13 years of experience providing tax consulting and compliance services extensively for clients in the financial services industry including PE/VC/hedge funds and fund managers, banks, brokerage houses, and insurance companies.

Roy regularly advises private equity funds and hedge funds on their Hong Kong and China tax issues at fund formation, in particular the applicability of Offshore Fund Exemption in Hong Kong, remuneration basis of the local sub-managers/advisors, carried interest planning and the potential issue in China on indirect transfer in equity. Roy is experienced in providing advice on the tax efficient structures for funds from profit repatriation and future exit perspectives. He also has extensive experience in providing tax consulting services to China based asset managers in Hong Kong in relation to their RQFII funds.

Apart from the above, Roy also advises banks and brokerage houses on various Hong Kong and China tax issues, from both direct tax and indirect tax (Hong Kong stamp duty and China VAT) perspectives. Roy are also advising a number of banks and brokerage houses on how to be in compliant with the requirements under Common Reporting Standard (CRS) in Hong Kong, Cayman Islands and BVI with respect to client onboarding, preexisting client due diligence and reporting.