Stefano Mariani

Deacons

Articles

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International tax alert: certificates of resident status (CoR) in Hong Kong

Hong Kong - August 8 2022 It is well-understood that the Hong Kong Inland Revenue Department ("IRD") will not issue a CoR to an applicant company that is treaty resident in…

Stamp Duty Alert: District Court holds that Limited Liability Partnerships may be associated bodies corporate for s.45 intra-group relief

Hong Kong, United Kingdom - July 20 2022 Limited liability partnerships (“LLPs”) and limited liability corporations (“LLCs”) are bodies corporate that have certain partnership-like…

Profits tax alert: Interposing business model held not taxable as profits-generating activity

Hong Kong - April 25 2022 Hong Kong has a territorial tax code: generally speaking, only the Hong Kong source profits of a trade, profession or business carried on in Hong…

Salaries tax alert: Payment of bonus shares to former employee and per diem for post-employment assistance to former employer held not taxable

Hong Kong - March 21 2022 When an employment relationship comes to an end, it is not uncommon for the parties to enter into a termination agreement setting out the departing…

Mergers exempt from stamp duty

Hong Kong - August 19 2021 In a decision that will no doubt come as a great relief to the funds, banking, and asset management industries, the Court of Appeal ruled in Nomura…