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e20180718 Common HK tax issues on fund structure and latest development

Programme Code:
18 July 2028 (Tuesday)

Mr. Roy Phan, Tax Director, Deloitte China

CPD Hours:
Event Categories:
Application Form:
TIHK Webinar Seminar Registration Form_27May2020.pdf
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Asset management is an important financial services (FS) sector in Hong Kong.  As an international financial and asset management center, the Hong Kong SAR Government have been very proactive in formulating initiatives such as providing the Hong Kong profits tax exemption for the offshore private-equity funds, setting out the legal and regulatory framework for “open-ended fund companies”, etc for the purpose of attracting more funds and fund managers to be domiciled in Hong Kong.


Given now we are under a BEPS environment and with the increasing focus on tax transparency, the typical offshore fund management structure is currently under close scrutiny by the IRD (it is noted that the IRD have been conducting tax audits on offshore fund structures starting from few years ago) and therefore the taxability of management fee and carried interest earned by Cayman fund manager/general partner in a typical offshore fund structure is becoming an increasing focus for both the tax authorities and the industry players.


To give the audience an balanced overview of the Hong Kong tax issues that a typical offshore fund structure is facing and the foreseeable challenges/opportunities given the latest developments in global tax environment and domestic law changes, this seminar will cover the following topics:


– Typical offshore fund structures

– Hong Kong tax implications for fund and the exemptions available

– Taxation of management fee and carried interest

– Latest development of the fund exemption regime in Hong Kong


Speaker Profile

Roy is a tax director based in Hong Kong. He has more than 12 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.