In accordance with Articles 10 and 11 of the Master Plan of the Development of the Guangdong-Macao In-Depth Cooperation Zone in Hengqin (the “Plan”) promulgated by the State Council on 5 September 2021, eligible enterprises in the Guangdong-Macao In-Depth Cooperation Zone in Hengqin (the “Cooperation Zone”) are subject to a reduced corporate income tax (CIT) rate of 15%. As for the tourism, modern services and high technology businesses set up in the Cooperation Zone, the newly added earnings from overseas direct investment will be exempted from CIT. Domestic and international high-end talents and talents in short supply working in the Cooperation Zone shall be exempted from individual income tax (IIT) on the taxable income exceeding 15%.

In early 2022, the Monetary Authority of Macao Special Administrative Region (AMCM) issued the Guideline on Management and Operation of Private Investment Funds (the Guideline), which allows eligible managing entities to apply to the AMCM to establish “domestic private funds” in Macao – a new concept introduced under the Guideline. The move shows Macao’s determination to involve in the development of the Hengqin Cooperation Zone (short for Guangdong-Macao In-Depth Cooperation Zone in Hengqin) in financial sectors; it will also drive the upgrading of local industrial structure and a moderate diversification of industries. Based on the Guideline, the Guide on Establishment of Private Investment Funds and other AMCM rules, we will examine and analyse the procedures for establishing a private investment fund and its managing entities in Macao and the difficulties in the establishment.