Central management and control of an offshore Fund
The Inland Revenue Department has clarified the meaning of "central management and control" in the Departmental Interpretation and Practice Notes No. 43 to address the industry's concern about the residency requirement for directors of the management committee of offshore funds in their applications for profits tax exemption. The relevant information can be found as below:
https://www.ird.gov.hk/eng/new/index.htm
https://www.ird.gov.hk/eng/pdf/dipn43.pdf