Inland Revenue Ordinance (Cap. 112) (Version Date: 19/05/2023)

A new consolidated version of the Inland Revenue Ordinance was published on Hong Kong e-Legislation, the official website of the Department of Justice for publicizing legal documents.
The consolidated version contains the amendments made by the Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Bill 2022 which was passed by the Legislative Council on May 19, 2023. Specifically, it amends below noted parts and schedules to implement a new tax exemption regime for income derived from Family-owned Investment Holding Vehicles (FIHVs) managed by single family offices (SFOs). The now revised parts and schedules relate to the eligibility of assets, the conditions that must be fulfilled to be exempt (the management of the FIHVs primarily take place in Hong Kong; the NAV of the FIHV must be equal to or exceed HK$240 million; at least 95% of beneficial ownership in an FIHV is held by a single family member; or the single family office derives at least 75% of its income from managing an FIHV), and the definition and application of beforementioned beneficial ownership.
– Part 4 Profits Tax
– Part 6E Tax Treatment of Family-owned Investment Holding Vehicle and Family-owned Special Purpose Entity
– Part 14 Penalties and Offences
– Schedule 16C Classes of Assets Specified for Transactions for Purposes of Sections 20AN and 20AO and Schedule 16E
– Schedule 16E Tax Treatment of Family-owned Investment Holding Vehicle and Family-owned Special Purpose Entity
– Schedule 16F Provisions for Determining Extent of Beneficial Interest Family Member has in Particular Entity (Section 8 of Schedule 16E)
– Schedule 16G Provisions for Determining Extent of Beneficial Interest Unrelated Natural Person has in Particular Entity (Section 8 of Schedule 16E)
– Schedule 16H Provisions for Determining Extent of Beneficial Interest Entity has in Another Entity (Sections 8 and 20 of Schedule 16E)
– Schedule 16I Provisions for Determining Extent of FIHV’s Beneficial Interest in FSPE (Sections 11 and 16 of Schedule 16E)
– Schedule 16J Provisions for Ascertaining Amount of Assessable Profits of Resident Person under Section 22 of Schedule 16E
– Schedule 16K Provisions for Ascertaining Amount of Assessable Profits of Resident Person under Section 23 of Schedule 16E