Thu, Apr 26, 2018
A A A
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.’

I......................

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. Investing - Sequoia takes Facebook stake as shares slide in data controversy, $1.4b hedge fund sees intact fundamentals for Facebook, Jim Cramer reveals some 'suggested hedge fund trades' amid the Trump tariffs[more]

    Sequoia takes Facebook stake as shares slide in data controversy From Bloomberg.com: The $4.2 billion Sequoia Fund bought a small position in Facebook Inc. as the stock slid late in the first quarter, investment manager Ruane, Cunniff & Goldfarb told clients. "The recent controversy enab

  2. Activist Investors - Blue Sky-owned Wild Breads faces uncertain future[more]

    From AFR.com: A Blue Sky private equity investment in artisan-style baker Wild Breads enjoyed multiple valuation upgrades despite losing millions and breaching its lending covenants, accounts lodged with the regulator last week show. Wild Breads lost $2.4 million in 2017, but Blue Sky ascribed a hig

  3. Opalesque Exclusive: Barnegat to close hedge fund to outside investors on weak opportunities[more]

    Komfie Manalo, Opalesque Asia: Bob Treue's Barnegat Fund Management said it is closing its $666m fixed income relative value hedge fund to outside investors. "The negative side to gains in Fixed Income Arbitrage is that unless we find new opportunit

  4. Investing - Hedge fund makes a big bet on malls, British hedge fund manager Odey short UK government bonds on QE bet[more]

    Hedge fund makes a big bet on malls From Barrons.com: The dominant narrative on American shopping malls is that they're dead. Crushed by Amazon.com, many brick-and-mortar retail stores are destined for bankruptcy. And where is the most retail, clustered all together? Malls. From a

  5. Performance - Hedge funds suffer first back-to-back loss in two years, Netflix performance burns hedge fund short sellers, Macro hedge fund up 14.5% in first quarter sees dollar falling, Renaissance Technologies rebounds across hedge funds in March[more]

    Hedge funds suffer first back-to-back loss in two years From Bloomberg.com: Hedge Fund returns sank for a second straight month in March, the first back-to-back loss since the first two months of 2016, as trade wars, tech-sector woes and a Fed rate hike dragged down the S&P 500 from its