The Hong Kong government gazetted the Inland Revenue (Amendment) (No.2) Ordinance 2015 in July 2015 to extend the profits tax exemption for offshore funds to offshore private equity funds (“PE Fund Exemption”). Subsequent to the enactment of the above legislation, the Inland Revenue Department issued Departmental Interpretation & Practice Notes No. 51 (“DIPN 51”) to clarify some of the provisions in the legislation. While the new PE Fund Exemption offers greater tax certainty to offshore private equity funds and operational convenience to private equity fund managers, it also present some challenges.
Key topics covered:
Puay Khoon, Partner, Financial Services – Tax, PwC Hong Kong
Puay Khoon specialises in the asset management industry and banking and capital markets industry. She has extensive experience serving China based as well as global and regional financial services clients. She has assisted many private equity and hedge fund clients establish their fund and fund management structures and is experienced in advising on investment structures, funding structures, structured finance products, tax compliance work, and health check. Puay Khoon has been involved in transaction and deal related work such as tax due diligence, merger and acquisition. She has assisted a number of private equity funds to apply for treaty benefits in China and repatriate investment proceeds out of China. She has been practicing tax for more than 13 years. In addition to Hong Kong tax, Puay Khoon is also familiar with Singapore tax and China tax having spent some time in each of these jurisdictions. She spent almost two years in Beijing practicing China tax before returning to Hong Kong. Puay Khoon is a CFA charter holder and a Chartered Accountant.
This workshop is suitable for investment professionals and anyone who is interested in gaining an understanding of the new PE Fund Exemption and DIPN 51 to the private equity fund industry.