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據報本港擬大幅修訂附帶權益相關法例 資管公司績效費或將完全免稅
據英國《金融時報》報道,香港正計劃大幅修訂附帶權益相關法例,可能允許許多資產管理公司賺取的績效費毋須繳納任何稅款。報道指,一項即將提交立法會審議的法案,來自廣泛投資類別的利潤,將有資格作為附帶權益享受稅務待遇,而不僅限於私募股權交易。這項改變意味著對沖基金、私募股權、風險投資、私人信貸,甚至家族辦公室的經理人,可以透過架構安排,進一步降低他們本已低廉的香港稅...
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據報本港擬大幅修訂附帶權益相關法例 資管公司績效費或將完全免稅
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據英國《金融時報》報道,香港正計劃大幅修訂附帶權益相關法例,可能允許許多資產管理公司賺取的績效費毋須繳納任何稅款。

報道指,一項即將提交立法會審議的法案,來自廣泛投資類別的利潤,將有資格作為附帶權益享受稅務待遇,而不僅限於私募股權交易。

這項改變意味著對沖基金、私募股權、風險投資、私人信貸,甚至家族辦公室的經理人,可以透過架構安排,進一步降低他們本已低廉的香港稅單。報道引述三名知情人士透露,香港的目標是讓自身與杜拜等阿聯酋樞紐看齊,重新確立其在疫情後作為全球金融中心的復甦態勢。

一名熟悉該提案的人士表示,這有潛力成為稅務改革的一次「大爆炸」(Big bang)。如果一切成事,將會產生巨大影響。

「附帶權益」是指私募股權基金利潤中,在回報超過一定門檻後,分配給負責管理基金的普通合夥人的那部分利潤(有時是20%)。

在許多國家,附帶權益被視為資本利得而非普通收入,因此享有稅務優惠。香港對附帶權益設有0%的優惠稅率,但適用條件受限,有業界專家形容現行規定「繁重」。

根據提案,包括證券、衍生工具、現金及存款在內的多種資產所產生的基金利潤,均可構成附帶權益,因而有資格享受零稅率制度。

香港財經事務及庫務局發言人回應稱,政府建議優化基金、單一家族辦公室和附帶權益的稅務優惠制度。該發言人稱,改革是為了鞏固香港作為區內首要資產及財富管理中心的競爭力,並吸引更多基金和家族辦公室來港設立及營運。該發言人確認,政府計劃在2026年年中前提交修訂案,並強調與一般服務掛鉤的獎金及付款「將繼續按正常利得稅稅率徵稅」。(da/u)

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