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The Hong Kong Legislative Council passed the Revenue (Profits Tax Exemption for Offshore Funds) Bill 2005 on 1 March 2006. The new law will amend the Inland Revenue Ordinance, whereby: - an offshore fund entity (which covers individuals, partnerships, corporations and trustees of trust estates) would be exempt from profits tax if it is a non-resident entity and does not carry on any business in Hong Kong other than "qualifying transactions" or transactions that are incidental to these; - "qualifying transactions" are transactions that are typically carried out by offshore funds in Hong Kong including transactions in securities,...