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20240626 Tax Sharing: Practical considerations of family office regime in Hong Kong

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Programme Code:
20240626
Date:
26 June 2024 (Wednesday)
Time:
6:30 pm - 8:00 pm
Speakers:

Ms Sophia Chan, Partner, Tax Services, PwC Hong Kong

Ms Wise Lam, Partner, Private Clients and Family Office Services

Language:
Cantonese
Venue:
ET 2101-2, 21/F, Edinburgh Tower The Landmark 15 Queen’s Road Central, Central Hong Kong
Proficiency Level:
Intermediate level
Fee:
$150 – $200
CPD Hours:
1.5
Seat:
75
Event Categories:
,
Application Form:
20240626 enrolment form

Description

The Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance 2023 (the Ordinance) was gazetted and came into operation on 19 May 2023. The Ordinance provides profits tax concessions for eligible Family-owned Investment Holding Vehicles (FIHVs) managed by eligible Single Family Offices (SFOs) in Hong Kong; and Family-owned Special Purpose Entities (FSPEs). Only the assessable profits of FIHVs and FSPEs arising from qualifying transactions and incidental transactions are eligible for profits tax concessions, which apply in respect of a year of assessment commencing on or after 1 April 2022.

The Inland Revenue Department (IRD) has provided some useful guidance in its website for taxpayers seeking to enjoy the tax concession. The IRD has also published Advance Ruling Case No. 73, the first ruling in respect of the new family office tax regime, for taxpayers’ reference.

In this seminar, the speakers will cover the following:

  • Give a brief background on the development of family offices in Hong Kong
  • Discuss the IRD guidance
  • Explore the key issues in the Advance Ruling Case No. 73
  • Share practical considerations involved in the above advance ruling application, and common issues in setting up family office structures

Speaker Profile

Ms Sophia Chan, Partner, Tax Services, PwC Hong Kong

She is a Tax Partner specialized in Hong Kong and international tax. The projects she worked on include corporate and operation structuring for initial public offering, cross-border transactions, tax due diligence review and tax dispute and resolution. In recent years, Sophia also helps her multinational clients with global business presence to prepare for the rollout of BEPS Pillar 2.

Sophia’s clients are mainly from Consumer Markets and Technology Sectors and she has worked on various tax consulting projects of these clients including:

  • Assisted a multinational corporation to structure their family office in Hong Kong and obtained the first positive ruling for tax concessions for family-owned investment holding vehicles in Hong Kong;
  • Assisted multinational corporations to assess the impact of BEPS Pillar 2 to their groups and plan for restructuring of their business models and holding structures to prepare for the changes; and
  • Acted as a sell-side tax advisor for a multinational logistics client in a significant merger and acquisition transaction of over HK$20 billion and the pre and post deal restructuring.

Sophia obtained her Bachelor of Business Administration degree and Professional Diploma in China Accounting, Finance, Taxation and Law from the Chinese University of Hong Kong in 2001 and 2007 respectively.  She is a Fellow Member of ACCA, CPA of HKICPA and a member of the Taxation Institute of Hong Kong.  She is a member of the Taxation Faculty Executive Committee of HKICPA in 2024.

 

Ms Wise Lam, Partner, Private Clients and Family Office Services

Wise is a Tax Partner of Private Clients and Family Office Services in PwC. She has been providing consultation services for high-net-worth individuals and families, including well-known individuals, major shareholders and senior executives for pre-IPO and post-IPO structures, on relevant family wealth, succession and international tax planning by setting up appropriate structures, including family trusts, employee trusts, charitable organisations, restructuring of offshore structures, etc.

Wise has been providing trust and wealth planning advisory services to high-net-worth individuals and listed companies including providing advice in relation to international taxation, asset preservation and wealth planning; employee incentive structure planning for the major shareholders and senior executives of companies to be listed in Hong Kong or United States; setting up and restructuring of offshore holding structure including trust structures, Hong Kong companies and offshore companies; assistance with the trust administration, restructuring and ongoing operations; and planning and implementation of family governance structures.

Wise is a TEP, a member of HKICPA and ICAEW and also holds a Master of Laws.

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