An Update on the Recent IRD Tax Audit on the Fund Management Industry

In the past few years, the Inland Revenue Department (IRD) has embarked on the review of the fund management industry. Their work concentrated on the taxability of the offshore fund manager and whether the investment advisor in Hong Kong is properly remunerated.

This course will provide a practical overview of how to handle a tax audit with special attention on the tax audit implications for offshore funds & fund managers. The speakers will share with participants their experience on how to handle those fund manager tax audits. Between the 2 speakers they have helped clients to resolve over 20 cases. Some of them did not involve any adjustment.

Detailed Information

Highlights of the course include:

  • Brief background on the IRD tax audit
  • How does the IRD choose cases for tax audit
  • How to handle an IRD protective assessment
  • How to handle a tax audit on fund manager
    • Field audit and investigation process of the IRD
    • What should a taxpayer do when they receive a letter for tax audit
    • The importance of the IRD interview on fund manager tax audit
    • Issues to consider when trying to resolve the audit e.g. transfer pricing issues for fund manager
    • Ways and means to resolve a tax audit case. For example offshore claim for fund manager
    • Case studies
  • Update on the IRD’s recent issuance of new DIPN No. 51 and revised DIPN No. 43, including the IRD’s views on carried interest arrangement for corporates and individuals
  • Way forward – Prevention is better than cure
  • Q&A

Registration Conditions

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