Tax considerations for funds structuring in Asia Vincent Ooi
By: Ooi, Vincent
.
Material type: 
ArticlePublisher: 2020Subject(s): FONDOS DE INVERSION | IMPUESTOS | INCENTIVOS FISCALES | ASIAOnline resources: Click here to access online
In:
Journal of Taxation of Investments v. 38, n. 1, Fall 2020, p. 49-62Summary: Tax considerations play a major role in the decisions of fund managers about where to base their funds. The highly mobile nature of capital has resulted in tax competition, leading to several host jurisdictions for funds in Asia (Hong Kong, Singapore, Labuan, and the BVI) having very similar tax characteristics in terms of
low effective corporate income tax rates, no capital gains taxes, no exit taxes, a single tier of taxation, and generally no withholding taxes. Other ways in which jurisdictions have attempted to distinguish themselves include a strong Double Tax Agreement network, certainty on the taxation of any carried interest, and offering a segregated portfolio company structure. Offering a segregated portfolio company structure is particularly important to promote local domiciliation of funds. Hong Kong is now the only one of the
four jurisdictions in this study that does not offer such a structure.
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| OP 235/2020/1-1 Taxation as a barrier to blockchain innovation | OP 235/2020/1-2 Market reactions to IBOR transition proposed tax regulations | OP 235/2020/1-3 The "carried interest" rules of Section 1061 | OP 235/2020/1-4 Tax considerations for funds structuring in Asia | OP 235/2020/1-5 A note on Public Pension Plan Funding | OP 235/2020/1-6 The proposed Section 1031 regulations after the TCJA | OP 235/2020/1-7 When is an investment loss deductible? |
Disponible también en formato electrónico.
Resumen.
Tax considerations play a major role in the decisions of fund managers about where to base their funds. The highly mobile nature of capital has resulted in tax competition, leading to several host jurisdictions for funds in Asia (Hong Kong, Singapore, Labuan, and the BVI) having very similar tax characteristics in terms of
low effective corporate income tax rates, no capital gains taxes, no exit taxes, a single tier of taxation, and generally no withholding taxes. Other ways in which jurisdictions have attempted to distinguish themselves include a strong Double Tax Agreement network, certainty on the taxation of any carried interest, and offering a segregated portfolio company structure. Offering a segregated portfolio company structure is particularly important to promote local domiciliation of funds. Hong Kong is now the only one of the
four jurisdictions in this study that does not offer such a structure.
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