Part 6 Deemed Assessable Profits under section 20AE, 20AF, 20AX and / or 20AY of the Inland Revenue Ordinance
(i)
the assessable profits of a non-resident person /
special purpose vehicle beneficially owned by a
non-resident person are exempt from tax under
section 20AC / 20ACA of the Inland Revenue
Ordinance, and the non-resident person is your
associate or you, alone or jointly with your
associate(s), hold 30% or more of beneficial
interest in the non-resident person;
(ii)
for the year of assessment 2019/20 and subsequent
years, the assessable profits of a fund falling
within the meaning given by section 20AM of the
Inland Revenue Ordinance are exempt from tax under
section 20AN of the Inland Revenue Ordinance, and
during any part of the year the fund is your
associate or you (alone or jointly with any of
your associates) hold a beneficial interest of 30%
or more in the fund; or
(iii)
for the year of assessment 2019/20 and subsequent
years, the assessable profits of a special purpose
entity, in which a fund satisfying (ii) above has
a beneficial interest, are exempt from tax under
section 20AO of the Inland Revenue Ordinance.
(May 2026)