Wed, Oct 7, 2015
Welcome Guest
Free Trial RSS
Get FREE trial access to our award winning publications
Alternative Market Briefing

Other Voices: How new rules clarification will affect Hong Kong-based advisors of Cayman funds

Thursday, July 01, 2010

This article was written by David Lyons of Caymans and Ireland-based hedge fund service provider dms Management, and by Dawn Cummings of Offshore Business Solutions, also located in the Caymans.

A recent clarification of the rules for interpreting “central management and control” as it relates to offshore funds in Hong Kong has sought to make this grey area of tax exemption a bit clearer. The clarification, which addresses the issue of residency of directors, arguably provides investment managers and advisors with a greater perspective on the issues they must address in achieving a successful application for a profits tax exemption for offshore vehicles. Dawn Cummings and David Lyons explore the finer points of what this will mean for Hong Kong based advisors of Cayman domiciled funds.

The Hong Kong Internal Revenue Department (“IRD”) clarification that came into play on 24 February, 2010, was announced in March during the Budget Speech by the Financial Secretary, the Honorable John Tsang. Since the offer of exemption was introduced in 2006, there has been some confusion over what role, if any, the residence of individual directors played in determining a company’s central management and control. The IRD clarification now maintains that residency is not generally a criterion in assessing the locus of ‘central management and control.’


To view our full article Click here

Today's Exclusives Today's Other Voices More Exclusives
Previous Opalesque Exclusives                                  
More Other Voices
Previous Other Voices                                               
Access Alternative Market Briefing

  • Top Forwarded
  • Top Tracked
  • Top Searched
  1. U.S. hedge funds prepare for worst finish this year since 2008[more]

    Komfie Manalo, Opalesque Asia: U.S.-focused hedge funds are preparing for their worst year since the 2008 global financial crisis, following a series of letdown including the market sell-off in August and the sell-off in healthcare and biotechnology sectors last month, reported

  2. Investing - AQR Capital and Renaissance Technologies raise stakes in Southwest Airlines[more]

    From In the previous part of this series, we saw how institutional investors played Southwest Airlines (LUV) in 2Q15. Now let’s move on to the trades executed by key hedge funds in Southwest Airlines over the same period. … Most of the hedge funds that had significant exposu

  3. DoubleLine’s Jeffrey Gundlach warns of another round of market shakedown[more]

    Komfie Manalo, Opalesque Asia: DoubleLine Capital co-founder Jeffrey Gundlach is painting a bleak future as he warned that the U.S. equity market and other risk markets, such as high-yield "junk" bonds, are facing another round of selling pressure. Gundlach said in an interview with

  4. A hedge fund strategy that seems to have fizzled[more]

    From The hedge fund strategy that has attracted the most money this year is on course to cause some of the biggest losses for investors, in the latest example of the dangers of going with the crowd. Institutions and individuals have piled an estimated $20 billion (Dh73 billion) into ma

  5. Hedge fund Barnegat survives September’s market selloff[more]

    Komfie Manalo, Opalesque Asia: Bob Treue’s $679 million Barnegat Fund proved resilient after another month of market letdown as the hedge fund gained 2.2% last month, bringing its year-to-date gains to 2.8%. Treue said in his monthly report to i