2021-09-01-德勤-香港税收新政如何吸引私募基金进驻香港_11页_361kb

Hong Kong introduced a new tax policy to exempt carried interest from taxation in specific conditions to attract private equity funds. The policy involves four key criteria: (1) Eligible carried interest must derive from approved private equity transactions, (2) A qualifying payer must be certified as a compliant fund by the Hong Kong Monetary Authority (HKMA), (3) Qualifying transactions must involve specific investment management services provided in Hong Kong, and (4) Recipients must undergo identity verification to determine their eligibility status (A, B, or C).

The certification process is administered by the HKMA, requiring funds to submit applications with relevant documentation to obtain approval. During the review, the HKMA verifies that the fund fulfills the necessary criteria, including attestation of local employment and spending requirements. Certified funds must engage external auditors annually to confirm ongoing compliance.

This policy addresses several implications. Hong Kong enhances its competitiveness against Singapore by offering favorable tax conditions. However, its effectiveness depends on whether these measures align with international tax standards and whether they retain existing funds while deterring opportunistic behavior. Factors such as Singapore's tax incentives, geographic appeal, and quality of life for expatriate professionals pose significant competition.

The economic benefits predicted by Hong Kong authorities are contingent on successfully attracting funds and generating substantial economic activity. Future outcomes depend on the policy's implementation, domestic and international acceptance, and whether Hong Kong can bridge its position relative to rivals facing similar or more attractive incentives.