Structuring for Hong Kong listings
Our tax group advises on tax aspects of pre-IPO asset or company restructuring, stamp duty minimisation; uses of offshore trading, service, licensing, finance and holding companies to increase the group’s overall tax efficiency. We also advise the principal shareholders of the listed company on the uses of offshore vehicles (trusts, unit trusts, companies) for holding shares for tax, asset protection and succession planning reasons. We advise substantial shareholders on the disclosure requirements and other compliance requirements under the Hong Kong Securities and Futures Ordinance.
Structuring for Mergers and Acquisitions
We have extensive experience in advising both the vendors and purchasers on asset / company buy and sale transactions regarding the tax implications, stamp duty avoidance, allocation of price among assets, financing arrangement to maximize tax deductions.
Structuring for Offshore Funds and Fund Manager Arrangements
We advise on the Hong Kong tax positions of offshore funds and structuring offshore manager arrangements, structuring of asset acquisition and disposals and tax planning for high-net-assets individuals / family offices.
Our tax group also advises financial institutions on tax aspects of their business set-up, onshore and offshore banking services; all tax issues relating to the different types of investment funds, investment products.
Telecommunication and Real Estate Developers
We advise telecommunication players on the treatment of royalties, structuring offshore licensing arrangements and real estate developers on captive insurance schemes, property redevelopment schemes and offshore financing transactions.
Setting up of Operations in Hong Kong
We advise on the setting up of branch vs subsidiary in Hong Kong, issues on the source of profits, interest deduction on intra-group debt, capitalization and home country tax issues, uses of tax haven holding companies and application of double tax treaties, uses of start-up losses, withholding tax issues on remittance of profits, repatriation of money to the host country in the form of dividend, royalties, interests and management fees.
Tax Investigation / Litigation
We advise clients and liaise with the tax authorities on field audits, tax investigation cases, civil and criminal litigation procedures.