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Carried interest tax concessions set to strengthen Hong Kong SAR s private equity industry
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Zero % Tax for Hong Kong s Carried Interest Tax Concession
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Unified Funds
Tax Exemption Ordinance ) and sets outs intended IRD
practice in administering the Unified Funds Tax Exemption which
came into effect on April 1, 2019.
The Unified Funds Tax Exemption
The Unified Funds Tax Exemption seeks to exempt hedge funds,
including OFCs and LPFs, from Hong Kong profits tax. This exemption
may apply regardless of the fund structure, location of the
fund s central management and control, fund size or fund
purpose provided that prescribed conditions are satisfied.
Unlike the Offshore Funds Exemption, there is no longer a bias
against Hong Kong. Firstly, there is no longer any need to
artificially maintain fund management and control overseas.
The adoption of HKFRS 15 is likely to lead to significant changes for revenue recognition
The Inland Revenue Department (IRD) issued an updated guidance Departmental Interpretation and Practice Notes No. 1 (DIPN 1) on: (a) computing assessable profits; (b) revenue recognition under HKFRS 15: Revenue from Contracts with Customers; and (c) measurement of inventories or stock.
The updated guidance primarily sets out the IRD’s views and assessing practice under HKFRS 15, and contains examples illustrating the accounting and tax treatments; and the stock valuation methods for tax purposes.
Part A: Computation of assessable profits
The updated DIPN 1 outlines the core principles for computing assessable profits on revenue derived from customer contracts under HKFRS 15. In particular: