Publication Type

Journal Article

Version

submittedVersion

Publication Date

10-2020

Abstract

Tax considerations play a major role in the decisions of fund managers of 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 the carried interest, and in 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.

Keywords

Taxation Law, Tax Law, Taxation, Funds, International Tax, Asia

Discipline

Asian Studies | Taxation | Tax Law

Research Areas

Corporate, Finance and Securities Law

Publication

Journal of Taxation of Investments

Volume

38

Issue

1

First Page

49

Last Page

62

ISSN

0747-9115

Publisher

Civic Research Institute

Copyright Owner and License

Authors

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