Asset Management

Unified Fund Exemption Regime



As part of the Hong Kong SAR Government’s effort to demonstrate to the Council of the European Union (“EU”) as a cooperative jurisdiction, Hong Kong has introduced the Inland Revenue (Profits Tax Exemption for Funds) (Amendment) Ordinance 2019, the so-called Unified Fund Exemption Regime (“UFE”), effective 1 April 2019 removing all the ring-fencing features identified by the EU under the existing offshore fund exemption regimes (“OFE”). The UFE also substitutes the previous profits tax exemption regime specific for open-ended fund companies which was introduced in March 2018.


With the recent enactment of the new economic substance legislations by various low or no tax jurisdictions such as the Cayman Islands and British Virgin Islands, the new UFE impact the Hong Kong asset management industry from a tax perspective will be assessed. Will the UFE lead to opportunities for asset management groups to simplify and streamline their operating protocol? What are the risk areas fund managers should be mindful of in restructuring their fund management businesses?


In this seminar, the following will be discussed:-
- What fund means under the UFE;
- What has been changed from the OFE and what stays the same;
- How may the UFE help with the substance requirements in the Cayman Islands and BVI;
- What are the key considerations and risks for on shoring offshore fund managers;
- Case sharing of common pain points.

Who should attend

Fund managers, asset managers and investors who would like to have a better understanding of the tax issues under UFE.

Financial Incentive Scheme of the WAM Pilot Programme

This is one of the eligible courses / seminars / conferences under the Financial Incentive Scheme (“The Scheme”) of the WAM Pilot Programme.

Eligible in-service practitioners of the financial services industry could apply for reimbursement of 80% of the course fees, subject to a maximum of HK$7,000 (whichever is lower) upon satisfactory completion of a course / seminar / conference over the three-year period of the Scheme.

Each individual may apply for reimbursement for more than one course / seminar / conference.

Application to reimburse the course fees, together with the required documents, must be submitted within four months from the last day of the course / seminar / conference attended. Please refer to the WAM Pilot Programme website for more details.

Speaker/Course Instructor

Agnes has over 20 years of professional experiences gained from international accounting firms. She focuses on tax issues related to group restructuring, merger and acquisition and other cross-border transactions. Agnes also has extensive experiences in advising asset management firms including private equity, venture capital and hedge funds on structuring and tax issues, including field audit and tax investigation by the Inland Revenue Department. Agnes has been a frequent contributor to the development of tax industry. She was heavily involved in lobbying the Hong Kong Government on the new offshore fund and onshore fund law. She was a technical reviewer for Wolters Kluwer’s Hong Kong Master Tax Guide from 2008 to 2016. She is currently a member of the Taxation Faculty Executive Committee of the Hong Kong Institute of Certified Public Accountants, as well as fellow of the Association of Chartered Certified Accountants and the Taxation Institute of Hong Kong.


Date & Time
Thursday, 27 Jun 2019 (12:20PM - 1:20PM)
HKSI Institute Training Centre
Relevant Subject
Type 9 - Asset management
SFC:1.00, PWMA:1.00