TAX
SERVICES

Our legal team advises hedge fund managers on managing their own tax liabilities in Hong Kong as well as tax liabilities in Hong Kong of the funds that they manage. The latter includes eligibility for and the application of profits tax exemptions under the unified funds tax exemption regime under the Inland Revenue Ordinance (“IRO”). We advise on corporate structures for management groups taking into account base erosion and profit shifting (“BEPS”) measures and the general anti-avoidance provisions (“GAAR”) of the IRO.

We advise general partners (“GPs”) and private equity fund advisors on tax efficient structures for providing advisory and management services to the funds sponsored by them, including advising on corporate structure, and the treatment of carried interest and management fees. We assist with global structuring of sponsor groups, taking into account transfer pricing tax considerations under general anti-avoidance provisions (“GAAR”) and base erosion profit shifting (“BEPS”) provisions under the Inland Revenue Ordinance (“IRO”).

We advise private equity sponsors on the application of tax exemptions for profits tax in respect of the fund vehicle as well as holding vehicles. We advise private equity sponsors on the structure for investing to ensure the tax efficient distribution of gains and losses from investments to limited partners (“LPs”), taking into account tax exemptions and deductions as well as provisions of comprehensive double taxation agreements (“CDTA”).