Transcription of Departmental Interpretation And Practice Notes - No
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Departmental Interpretation And Practice Notes - No
Inland Revenue Department Hong Kong Departmental Interpretation AND Practice Notes NO. 51 PROFITS TAX PROFITS TAX EXEMPTION FOR OFFSHORE PRIVATE EQUITY FUNDS These Notes are issued for the information of taxpayers and their tax representatives. They contain the Department s Interpretation and practices in relation to the laws as it stood at the date of publication. Taxpayers are reminded that their right of objection against the assessment and their right of appeal to the Commissioner, the Board of Review or the Court are not affected by the application of these Notes . WONG Kuen-fai Commissioner of Inland Revenue May 2016 Our web site : Departmental Interpretation AND Practice Notes No. 51 CONTENT Paragraph Introduction Relevant legislation 1 Private equity funds Nature of private equity funds 2 Fund lifecycle 3 Fund structure 5 Before the 2015 Ordinance Specified transactions and specified person 6 Securities of private companies excluded 8 The 2015 Ordinance Aim of amendment ordinance 10 Exemption extended to private equity funds Expanded definition of securities 12 Special purpose vehicle 14 Excepted private company 16 - Definition of private company 17 - Three-year time frame 19 - Safe harbour rules 20 - Permanent establishment of private company 28 Funds not engaging a specified person Qualifying fund 33 Number of investors 40 Capital commitment 41 Net proceeds 42 Speci
inland revenue department hong kong. departmental interpretation and practice notes . no. 51 profits tax . profits tax exemption for offshore private equity funds
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