Notes On Tax Structuring Or Planning (to be updated)

1. Notes on Tax Structuring or Planning
The purpose of tax structuring or planning in an
acquisition (either share sale or asset sale)
. to minimize the tax obligations to the target company
- minimize corporate tax : maximize tax deductible
interest payments, i.e. by optimizing gearing ratio based
on thin capitalization rule
..
.
. to maximize the cashflow to the shareholders of the
target company
- properly structure & set up off-shore companies to
minimize quot;withholding taxquot; during repatriation of
quot;return, profit or cashquot; back to quot;HKquot; and quot;capital gain
taxquot; during potential sale of business
- reduce cash trap in the project company by using
shareholder loan
..
.