e20180718 Common HK tax issues on fund structure and latest development
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