As part of the Hong Kong SAR Government’s effort to demonstrate to the Council of the European Union (“EU”) as a cooperative jurisdiction, Hong Kong has introduced the Inland Revenue (Profits Tax Exemption for Funds) (Amendment) Ordinance 2019, the so-called Unified Fund Exemption Regime (“UFE”), effective 1 April 2019 removing all the ring-fencing features identified by the EU under the existing offshore fund exemption regimes (“OFE”). The UFE also substitutes the previous profits tax exemption regime specific for open-ended fund companies which was introduced in March 2018.

With the recent enactment of the new economic substance legislations by various low or no tax jurisdictions such as the Cayman Islands and British Virgin Islands, the new UFE impact the Hong Kong asset management industry from a tax perspective will be assessed. Will the UFE lead to opportunities for asset management groups to simplify and streamline their operating protocol? What are the risk areas fund managers should be mindful of in restructuring their fund management businesses?

In this seminar, the following will be discussed:-
- What fund means under the UFE;
- What has been changed from the OFE and what stays the same;
- How may the UFE help with the substance requirements in the Cayman Islands and BVI;
- What are the key considerations and risks for on shoring offshore fund managers;
- Case sharing of common pain points.

Fund managers, asset managers and investors who would like to have a better understanding of the tax issues under UFE.

Administrative Details