1. 1
A BRIEF GUIDE TO CHOOSING YOUR LISTING DESTINATION
(A COMPARISON BETWEEN LISTING ON BURSA MALAYSIA AND HONG KONG STOCK EXCHANGE)
25 February 2015
About The Author
ONG YEE CHEE, is an associate with
the corporate finance department at Ben
& Partners
Gen: +6(03) 7805 2922
Fax: +6(03) 7805 3922
Mobile: +60(19) 481 6669
Email: yeechee@benpartners.com
INTRODUCTION
The business environment is dynamic with opportunities always
available to businessmen who have the adequate level of capital not
only to sustain its daily operational requirements but more
importantly, be able to capitalise on such opportunities to create
value for all stakeholders.
One of the options opened to any business is to tap the capital
markets for funds to support its growth initiatives be it through
organic means or via mergers and acquisitions. An initial public
offering (IPO) is an option to position the business to tap funds from
the capital market, given that cost of funds are cheaper with more
avenues to raise capital compared to sourcing of financing from the
traditional channels where personal guarantee is normally the norm.
A listed company with its inherent benefits such as, perceived to be
more transparent, visible to all stakeholders and acting as a
barometer for the worth of the business can be tapped further to
scale the business higher by exploiting the capital markets for
additional funds or even use the listed securities as an option to
finance mergers and acquisition.
This article is intended to give you an option to consider listing your
business on the Main Market in Malaysia and Hong Kong.
Should you have any query, we would be most pleased to address
them.
DISCLAIMER:
The contents of the articles, views and
opinions are intended to provide general
information only and should no be
construed as legal advice or legal opinion.
The firm bears no responsibility and we do
not warrant its accuracy or completeness or
accept any liability for any loss or damage
arising from any reliance on the information
contained therein.
Please do not reproduce, transmit or
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permission or from the firm.
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Advocates and Solicitors

2. A Comparison Between Listing on Bursa Malaysia And Hong Kong Stock Exchange 2
THE LISTING REQUIREMENTS
A brief comparison on the listing requirements between Malaysia and Hong Kong.
Malaysian IPO (Main Market) (“MIPO”) Hong Kong IPO (Main Board) (“HKIPO”)
(A) Financial Requirements (A) Financial Requirements
1. Profit Test (a) Profit after tax
(“PAT”) of at least
RM20 million in the
last 3 to 5 financial
years; and
(b) PAT of at least RM6
million for the most
recent full financial
year
1. Profit Test (a) PAT of at least
HK$50 million in the
last 3 financial
years; and
(b) PAT of at least
HK$20 million for
the most recent full
financial year
2. Market
Capitalization
Test
(a) Upon listing total
market capitalization
of at least RM500
million; and
(b) Generated operating
revenue for at least
1 full financial year
prior to submission
2. Market
Capitalization
and Revenue
Test
(a) Upon listing total
market
capitalization of at
least HK$4 billion;
and
(b) Total revenue of at
least HK$500 million
for the most recent
audited financial
year
3. Market
Capitalization,
Revenue and
Cashflow Test
(a) Not applicable in
Malaysia
3. Market
Capitalization,
Revenue and
Cashflow Test
(a) Total market
capitalization of
HK$200 million
upon listing; and
(b) Total revenue of at
least HK$500 million
for the most recent
audited financial
year; and;
(c) Positive cashflow
from operating
activities of at least
HK$100 million in
aggregate for the 3
preceding financial
years
4. Infrastructure (a) Right to build and 4. Infrastructure (a) Right to build and

3. A Comparison Between Listing on Bursa Malaysia And Hong Kong Stock Exchange 3
Project
Corporation
Test
operate
infrastructure
project, with project
costs of not less than
RM500 million; and
(b) Remaining
concession period of
at least 15 years
Project
Corporation
Test
operate
infrastructure
project, with project
costs of not less
than HKD1 billion;
and
(b) Remaining
concession of at
least 15 years
(B) Operating History and
Management Requirement
(B) Operating History and
Management Requirement
1. With an identifiable core business which it
has majority ownership and management
control
2. At least 3 full financial years of continuity
of substantially the same management
3. Applicant under the Capitalization Test
must be able to sustain the same
management since the commencement of
operations (if less than 3 full financial
years)
1. Ownership continuity and control for at
least the most recent audited financial
year
2. At least 3 preceding financial years of
management continuity
3. Applicant under the Market Capitalization
and Revenue Test, the Stock Exchange of
Hong Kong Limited (“HKEx”) will accept a
shorter trading record period if the
directors and management have sufficient
and satisfactory experience of at least 3
years of business and industry of the
applicant and the new applicant has
management continuity for the most
recent audited financial year
(C) Public Float (C) Public Float
1. At least 25% of total listed shares
(excluding treasury shares) must be held
by public
1. At least 25% of the issuer’s total issued
share capital must at all times be held by
the public
2. Where expected market capitalization is
over HK$10 billion upon listing, HKEx may
accept a lower percentage in between
15% and 25%
(D) Spread of Shareholders (D) Spread of Shareholders
1. Minimum of 1,000 public shareholders
holding not less than 100 shares each
2. On best effort basis allocate to Bumiputera
investors 50% of the public spread
requirement
1. Minimum 300 public shareholders
2. Not more than 50% of the securities in
public hands upon listing

4. A Comparison Between Listing on Bursa Malaysia And Hong Kong Stock Exchange 4
As a summary to the above, the listing requirements for MIPO and HKIPO is relatively similar, save as
disclosed below:-
(A) Financial Requirement
(a) marginally higher PAT requirement for HKIPO and a shorter track record period;
(b) market capitalization, revenue and cashflow test is only applicable to HKIPO.
(B) Operating History and Management Requirement
(a) MIPO requires an identifiable core business which it has majority ownership and
management control, whereas HKIPO requires ownership continuity and control for at
least the most recent audited financial year;
(b) in addition to the management continuity which is applicable to both the MIPO and
HKIPO, for applicants under the Market Capitalization and Revenue Test HKEx will accept
a shorter trading record period if the directors and management have sufficient and
satisfactory experience of at least 3 years of business and industry of the applicant.
(C) Public Float
(a) HKEx may accept a lower percentage in between 15% and 25% if the expected market
capitalization is over HK$10 billion upon listing;
(D) Spread of Shareholders
(a) MIPO requires a minimum of 1,000 public shareholders holding not less than 100 shares
each, whereas HKIPO only requires a minim of 300 public shareholders;
(b) it is on the best effort basis to allocate 50% of the public spread to Bumiputera investors
for MIPO, whereas HKIPO has no such requirement.
Apart from the abovementioned, there are certain flexibility in respect of listing of mineral companies
in HKEx (for further information, please refer to our article “LISTING OF MINERAL COMPANIES
IN HKEx”).

5. A Comparison Between Listing on Bursa Malaysia And Hong Kong Stock Exchange 5
IPO
Above are the key considerations to be taken into account upon deciding your listing destination.
PRICE EARNING
RATIO
LIQUIDITY AND
OTHER
CONSIDERATIONS OF
MARKET
LISTING
REQUIREMENTS

6. A Comparison Between Listing on Bursa Malaysia And Hong Kong Stock Exchange 6
CONCLUSION- WHY HONG KONG THE VENUE OF CHOICE?
HKEx is one of the largest stock exchanges in the world, has successfully raised a total equity funds
amounted to approximately HK$936 billion in 2014. As of 31 December 2014, HKEx (including the
Main Board and GEM) has 1,752 listed companies with an aggregate market capitalisation of over
HK$25 trillion.
Hong Kong is strategically placed in a high growth region and providing an ideal platform for issuers
to achieve exposure in the investors pools of the rapidly growing People’s Republic of China.
Apart from the aforesaid, it is important to highlight on the advanced clearing and settlement
infrastructure in Hong Kong. The Hong Kong Monetary Authority’s US Dollar Clearing System allows
financial institutions in Hong Kong to settle US dollars transactions real time in the Asian time zone
against the delivery of HK dollars and thus reduces the foreign exchange settlement risk caused by
the time gap between the settlement of HK dollars and US dollars.
The development of the new Listing Rules for mineral companies via Chapter 18, together with the
proximity to resource markets, has undoubtedly increased the interest of the mining sector towards
HKEx.
Below are inter alia, companies with Malaysian assets and operations which have been listed in
HKEx:-
1. Media Chinese International Limited (Stock Code 685)
2. Tan Chong International Limited (Stock Code 693)
3. CVM Minerals Limited (Stock Code 705)
4. Genting Hong Kong Limited (Stock Code 678)
5. V.S. International Group Limited (Stock Code 1002)
6. Parkson Retail Group Limited (Stock Code 3368)
7. CAA Resources Limited (Stock Code 2112)
8. Nirvana Asia Limited (Stock Code 1438)