Experience

Timothy Loh LLP Represents Fortune Global 500 Financial Institution in Tax Driven Corporate Restructuring

Our Tax Practice, Corporate Practice and Financial Services Regulatory Practice acted as Hong Kong counsel for a Fortune Global 500 financial institution in respect of tax and corporate issues arising from a major corporate restructuring.

Our lawyers were retained with specific focus on minimizing Hong Kong tax liabilities through the multi-stage group restructuring including:

  • application of intra-group associated company relief from stamp duty under section 45 of the Stamp Duty Ordinance (“SDO”) to U.S. registered limited liability companies (“LLCs”) without share capital

  • application of SDO provisions denying exemptive relief where companies cease to be associated within 2 years by reason of the statutory merger of corporate entities pursuant to U.S. law

  • management of Hong Kong regulatory issues arising from changes in shareholdings including applications to the Securities and Futures Commission (“HKSFC”) for approval of changes in substantial shareholders with particular focus on minimizing information to be provided by directors of parent holding companies

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