Asset and Wealth Management Tax Highlights – Asia Pacific · 2016-08-16 · which may impact your asset and wealth management business. We hope you find these updates of interest,

Asset and Wealth Management Tax Highlights – Asia Pacific

April to June 2016In this edition’s asset and wealth management tax highlights for the Asia Pacific region, we highlight industry and tax developments from Australia, Hong Kong, India, and Thailand, which may impact your asset and wealth management business. We hope you find these updates of interest, and will be pleased to discuss these developments and issues with you further.

Australia2016 – 2017 Budget measures

In the 2016-2017 Federal Budget, the Government announced a number of key corporate and superannuation tax measures as follows:

• A proposed reduction in the corporate tax rate to 25% over the next 10 years.

• A 40% “diverted profits tax” (DPT) to apply to large multinational companies for income years on or after 1 July 2017. These rules mirror the UK DPT and are designed to impose a penalty tax rate of 40% on profits transferred offshore through related party transactions with insufficient economic substance that reduce the tax paid by 20% or more. In addition, the Australian Taxation Office (ATO) is provided with wide powers to reconstruct alternative arrangements on which to tax the diverted profits. The DPT is a continuation of the Government’s focus on the perceived tax avoidance by multinationals and follows the recently enacted Multinational Anti-avoidance legislation (MAAL) which took effect form 1 January 2016.

• Tightening of the superannuation tax concessions for individuals to improve the sustainability and integrity of the superannuation system – the key measures include:

– Reducing the annual concessional contribution caps (i.e. from pre-tax employee earnings or deductible against self-employed income) to $25,000 per annum (from $30,000 for individuals under 50 years old and $35,000 for those over 50 years old).

– A lifetime cap of $500,000 for non-concessional contributions (i.e. from after tax earnings) which applies to all non-concessional contributions made from 1 July 2007.

– A limit of $1.6m that can be in pension phase (which is tax exempt). Any excess will be deemed to be in accumulation phase and taxed at 15%.

– Earnings from assets supporting benefits to individuals under “Transition to Retirement” are no longer tax exempt.

These measures have the potential to reduce the

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flow of funds into the superannuation system. They reflect a renewed intention that the superannuation system mitigates reliance on the age pension as opposed to provide an estate planning mechanism.

Following the re-election of the Government, it remains to be seen whether all of the above measures will be implemented.

New tax system for Attribution Managed Investment Trusts

The Bills implementing the new tax regime for attribution managed investment trusts (AMITs) and a number of related amendments were enacted on 5 May 2016. The new provisions are complex and far reaching in their impacts on fund managers, custodians and unit holders. Implementation of the new MIT regime will require changes to operations, service arrangements, reporting to investors and product planning and development.

To assist MITs in implementing the new regime:

• The ATO has provided a transitional period to 31 October 2016 for trustees to amend their constituent documents to have effect from 1 July 2016 (assuming the trustee elects to apply the new regime from 1 July 2016).

• The Australian Securities and Investments Commission (ASIC) has allowed amendments to the constitution without the requirement to hold a members’ meeting.

(Please refer to the October – December 2015 edition for a summary of the rules http://www.pwchk.com.hk/home/eng/am_tax_highlights_q42015.html)

Asia Region Funds Passport

On 28 April 2016 Australia, Japan, Korea and New Zealand signed a Memorandum of Cooperation (MOC) towards the commencement of the Asia Region Funds Passport. From 1 July 2016, any participating country can enact enabling domestic legislation to commence the passport, no later than 31 December 2017. In June following Cabinet approval, Thailand also signed the MOC.

To facilitate the launching of the Passport, the Government has announced it will introduce two new collective investment vehicles (CIVs), a corporate CIV (from 1 July 2017) and a limited partnership CIV (from 1 July 2018).

Loss recoupment measures

The Government released draft legislation on 6 April 2016 which extends the current loss recoupment tests for companies and listed widely held trusts to encourage innovation. Currently, for companies to be able to use prior year tax losses, they must satisfy the continuity of ownership test (COT), or failing that test, satisfy the same business test (SBT). Similar provisions also exist for listed widely held trusts. However, where new equity is injected, the SBT may discourage companies and listed widely held trusts from adapting to the new economic environment and entering into new businesses. Accordingly, the proposed measures introduce a more flexible “similar business” test which supplements the SBT.

Foreign currency hedging transactions

The ATO has issued Practical Compliance Guidelines PCG 2016/6 to provide further assistance to taxpayers in assessing the source of FX hedging transactions, and in interpreting TR 2014/7 (dealing with FX hedging gains and losses and the claiming of foreign income tax offsets). In PCG 2016/6, the ATO states it will accept certain methods of determining source of FX hedging gains (including the use of a representative sample of transactions) depending on the method of trading (i.e. manual trading versus electronic trading), the party executing the trade and the time period which the trade occurs (i.e. Australian hours versus offshore hours). The guidelines apply from 1 July 2015.

(Please refer to the January – March 2015 edition for a summary of the rules http://www.pwchk.com.hk/home/eng/am_tax_highlights_q12016.html)

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ATO interim guidance on 2016 trust distributions

This is a complex matter, so we have presented it in steps.

Preserving the CGT discount concession through trusts

• When a unit trust distributes a non-assessable amount (typically a return of capital, known as a ‘tax deferred’ amount), a unitholder is required to reduce the capital gains cost base of their units.

• An exception arises, where the non-assessable amount distributed represents the non-assessable CGT discount concession amount, in which case no cost base reduction is required.

• Without this exception, the CGT concession amount would be transformed into a tax deferred amount through a trust. Consequently, the CGT discount concession would be denied.

• This principle was extended to situations where a trust with capital losses receives a discount capital gain from another trust.

• This is consistent with policy, that an investor be in the same position when investing in a unit trust that they would have been, had they invested directly in the underlying assets of the trust.

Preserving the discount concession for trusts with capital losses

• The above extension of principle may also apply to situations where a trust with capital losses makes a discount capital gain, where the capital loss would reduce the nominal gain to nil, such that no CGT concession amount arises.

• Arguably, the amount that would have been the CGT concession amount (had there been no capital losses) may be distributed as an amount not requiring a cost base reduction (i.e. ‘loss recouped amounts’).

• The explanatory memorandum to the law provided examples confirming that no cost base reduction is required, which the ATO has quoted in issuing favourable private rulings on the matter.

Hong KongHong Kong is embarking on the BEPS journey

The Hong Kong Deputy Commissioner of Inland Revenue (Deputy CIR) commented on the implementation of the BEPS project in Hong Kong. One clear message that has emerged is that Hong Kong will need to respond to the rewritten international tax rules and update its tax system and legislation, at least in certain areas.

In implementing the BEPS project, priority will be given to the four BEPS action points where there are agreed minimum standards, namely (1) review of harmful tax practices and spontaneous exchange of information on certain tax rulings (Action 5), (2) model anti-treaty abuse provisions in tax treaties (Action 6), (3) country-by-country (CbC) reporting requirements and automatic exchange of CbC reports (Action 13) and (4) improvements in cross-border tax dispute resolution (Action 14). In particular, transfer pricing (TP) legislation and TP documentation requirements are likely to be the top priority. The Deputy CIR also hinted that the simplified limitation on benefits (LOB) rule plus the principle purposes test (PPT) will probably be the norm for Hong Kong tax treaties in the future.

With the likelihood of introduction of specific TP legislation and documentation requirements in Hong Kong, groups with cross-border related party transactions will need to prepare themselves for closer scrutiny by the IRD on TP-related issues and greater disclosure of TP-related information of the groups. With the possible incorporation of the simplified LOB rule and the PPT into the Hong Kong tax treaties, companies that hold their investments through Hong Kong investment holding platforms will need to review and assess whether their current structures can fulfil the conditions imposed by the new anti-treaty shopping rules and withstand potential challenges from Hong Kong’s tax treaty partners, and evaluate the options available to ensure the sustainability of such structures under the new rules.

For further details, please refer to the following URL: http://www.pwchk.com.hk/home/eng/hktax_news_may2016_4.html

Unintended outcomes may arise

• The ATO has recently become aware of a drafting anomaly, which can in some circumstances result in an unintended benefit to unitholders. Following consultation with industry, the ATO is proposing to issue a Tax Determination that is expected to limit the ordinary interpretation of the law, such that unintended outcomes do not arise.

• As Tax Determinations usually apply prospectively, the ATO has been concerned to limit unintended outcomes prior to the release of the Tax Determination.

• In an attempt to mitigate uncertainty, the ATO released a statement on 8 June 2016 to give trustees guidance for 30 June 2016 trust distributions. The statement indicates that trustees distributing loss recouped amounts should classify them as tax deferred, while at the same time suggesting that trustees receiving third party distributions may rely on the classifications they are provided, which may not require a cost base reduction, subject to changes that may be later advised.

Current position – uncertainty

To some extent, this has placed trustees in a delicate situation balancing the ordinary interpretation of the law (and the best interests of investors) with the ATO’s view (and the duty to mitigate litigation and the risks of consequential adjustments arising from a dispute with the ATO). Where the amounts are material, this can create legal issues for unitholders such as superannuation funds, where material changes in unit pricing can result in unintended wealth transfers between incoming and outgoing members.

Next steps

This is an ongoing matter which we will follow up in future newsletters.

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Hong Kong is now in a competitive position for setting up a regional corporate treasury centre

The Inland Revenue (Amendment) (No. 2) Ordinance (the Ordinance) on corporate treasury centres was gazetted on 26 May 2016. Amendments were made to the Inland Revenue Ordinance in the following three areas: (1) a concessionary profits tax rate for corporate treasury centres (CTCs), (2) new deduction rules for interest expenses incurred by an intra-group financing business and new deeming provisions on interest income and certain profits arising from such business, and (3) profits tax and stamp duty treatments in respect of regulatory capital securities (RCSs) issued by financial institutions.

The amendments related to (1) and (2) are basically the same as those proposed by the bill. As for the proposed amendments related to RCSs, the proposed section 17H regarding the application of the arm’s length and separate enterprise principles in circumstances other than those in connection with a RCS is now removed. Upon gazette of the Ordinance, the 8.25% tax rate applicable to CTCs and the new interest expense deduction rules for intra-group financing business will apply retrospectively from 1 April 2016 whereas the other provisions will apply from the commencement date of the Ordinance or the transitional year of assessment. Two Departmental Interpretation and Practice Notes will be issued to provide practical guidance on the new provisions on CTCs and RCSs respectively.

The new CTC tax regime puts Hong Kong in a competitive position when multinational corporations (MNCs) consider where in Asia to set up or relocate their regional CTCs. In considering where the best location is, MNCs should take into account both tax considerations and non-tax factors such as their own business needs and mode of operation as well as the regulatory environment, the financial and capital markets and the availability of finance talents in different locations.

For further details, please refer to the following URL: http://www.pwchk.com/home/eng/hktax_news_may2016_5.html

DIPN 51 and revised DIPN 43 on profits tax exemption for offshore funds (including offshore PE funds) were issued

The Inland Revenue Department (IRD) issued Departmental Interpretation and Practice Notes No. 51 (DIPN 51) on 31 May 2016 setting out its views on various issues relating to the application of the offshore private equity fund tax exemption regime. DIPN 43 was also revised at the same time to reflect the IRD’s latest interpretation and practice relating to the offshore fund tax exemption regime as a whole. While there is now clarity on some issues, some challenges and unanswered questions remain.

For further details, please refer to the following URL: http://www.pwchk.com/home/eng/fstax_news_jun2016.html

The Ordinance introducing the open-ended fund company regime in Hong Kong gazetted

The Hong Kong Government gazetted the Securities and Futures (Amendment) Ordinance on Friday 10 June 2016, introducing the legal, regulatory, and tax framework for an open-ended fund company (OFC) regime in Hong Kong.

For further details, please refer to the following URL: http://www.pwchk.com/home/eng/fstax_news_jun2016_2.html

Extension of the valid period of HKTRC for China/HK CDTA purpose and revised HKTRC application forms

Effective from 15 April 2016, a Hong Kong tax resident certificate (HKTRC) issued by the IRD for a calendar year can serve as a proof of the Hong Kong resident status for that calendar year and the two succeeding calendar years. However, if there are changes in the Hong Kong resident's circumstances such that the conditions for enjoying tax benefits under the China/HK comprehensive double tax arrangement (China/HK CDTA) are no longer met, such issued HKTRC will no longer be able to serve as a proof of the Hong Kong resident status after the changes. This streamlined administrative arrangement applies to all HKTRCs issued by the IRD in respect of the China/HK CDTA, including those issued before 15 April 2016.

The Bill implementing automatic exchange of information in Hong Kong is passed today

The Bill on implementing automatic exchange of information (AEOI) in Hong Kong is passed by the Legislative Council today. The Bill is passed without any amendments. The corresponding ordinance is expected to be published in the Gazette Friday next week.

Hong Kong has committed to commerce the first automatic information exchanges by the end of 2018. With the passage of the Bill, the next step will be for the HKSAR Government to identify an appropriate AEOI partner and signed a bilateral competent authority agreement on AEOI with it by the end of 2016.

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IndiaRegulatory updates

• Issuance of Rupee Denominated Bonds overseas – On 13 April 2016, the RBI issued a circular on issuance of rupee denominated bonds overseas which provided clarification and guidelines in respect of issuance limits, eligibility criteria for subscription and responsibility of issuer to maintain list of primary bond holders. Further, Frequently Asked Questions (FAQs) in respect to issuance of rupee denominated bonds overseas were also released.

• Change in Foreign Exchange Management Act (FEMA) 20 Schedule 6 – New revised Schedule 6 introduced – On 28 April 2016, the RBI issued a new FEMA notification replacing the existing schedule 6 for Foreign Venture Capital Investor (FVCI) investment with amended Schedule 6.

• Liberalisation of foreign investment limits for Asset Reconstruction Companies (ARC) – On 6 May 2016, the Department of Industrial Policy and Promotion (DIPP) issued a Press Note [Press Note No. 4 (2016 Series)] amending the conditions for foreign investment in ARCs in the Consolidated Foreign Domestic Investment (FDI) Policy Circular of 2015.

• Guidelines for public issue of units by Infrastructure Investment Trust (InvITs) – On 11 May 2016, the Securities and Exchange Board of India (SEBI) issued detailed guidelines relating to the public issue and allotment of units by an InvIT, and the advertisements relating to the offer.

• Cross border transfer of shares of an Indian company permitted on a deferred basis – On 20 May 2016, the RBI issued a notification to permit transfer of shares on a deferred basis, subject to compliance with certain conditions. These conditions need to be complied with for transfer of shares on a deferred basis between a resident buyer and a non-resident seller, or vice versa.

• Norms relating to issuance and transfer of offshore derivative instruments (ODIs) by FPIs – On 10 June 2016, the SEBI issued a circular requiring the FPIs to comply with certain norms relating to issuance and transfer of ODIs. The norms pertain to KYC, filing of suspicious transactions report, reporting of complete transfer trail, reconfirmation of ODI positions and periodic operational evaluation.

• Guidelines for sustainable structuring of stressed assets – On 13 June 2016, the RBI issued guidelines on a ‘Scheme for Sustainable Structuring of Stressed Assets’ as an optional framework for the resolution of large stressed accounts. The guidelines envisage the determination of the sustainable debt level for a stressed borrower, and the bifurcation of the outstanding debt into sustainable debt and equity/quasi-equity instruments.

• Changes in FDI policy regime – On 24 June 2016, DIPP issued press note liberalising the FDI policy in several sectors.

• Grand fathering of ODIs – On 29 June 2016, the SEBI issued a circular clarifying the position on grand fathering of ODI investments.The circular clarified that unregulated funds whose investment manager is appropriately regulated and was issued ODIs under the Foreign Institutional Investor (FII) regime can continue to hold the position until the date of expiry of such positions or until 31 December 2020, whichever is earlier. Such subscribers cannot take fresh positions or renew the old positions. Further, the circular also clarified that going forward, ODIs can only be subscribed by entities that meet the eligibility criteria under the regulations.

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Relaxation of rules for non-residents

On 24 June 2016, the CBDT notified relaxed rules regarding the information to be provided by non-residents where they do not have permanent account numbers (PAN) or tax identification numbers for India tax purposes. The implications of this is that the withholding tax (or TDS) at a higher rate of 20% will not be deducted if the following details / documents are provided:

i. name, e-mail id, contact number;

ii. address in the country of which the non-resident is a resident;

iii. Tax Residency Certificate (TRC) from the Government of that country if the law of that country provides for issuance of such certificate;

iv. Tax Identification Number (TIN) or any other Unique Identification Number of the non-resident of his residence country.

GAAR - grandfathering of investments made prior to 1 April 2017

On 22 June 2016, the CBDT amended Rule 10U of the Income-tax Rules 1962 (the Rules) on the application of GAAR. The changes address some of the concerns with respect to implementation of the GAAR provisions and provide certainty to taxpayers, and are set out below:

• The provisions of Chapter X-A (dealing with GAAR) will not apply to any income accruing or arising to or deemed to accrue or arise to or received or deemed to be received by any person from transfer of investments made before 1 April 2017.

• Without prejudice to the above, the provisions of Chapter X-A shall apply to any arrangement, irrespective of the date on which it has been entered into, in respect of tax benefit obtained from the arrangement on or after 1 April 2017.

• Only income from transfer of investments made prior to 1 April 2017 has been grandfathered.

Tax updates

Income / loss from transfer of unlisted shares to be deemed capital gains

On 2 May 2016, the Central Board of Direct Taxes (CBDT) issued an instruction providing that income from transfer of unlisted shares (for which no formal market exists for trading) would be treated as a ‘capital gain’ irrespective of period of holding.

Protocol for amendment of India-Mauritius tax treaty signed

On 10 May 2016, the Governments of India and Mauritius signed a Protocol for amending the treaty dated 24 August 1982, between India and Mauritius. The key features of the Protocol are the introduction of source-based taxation for capital gains on the transfer of Indian companies’ shares acquired on or after 1 April 2017, source-based taxation of interest income of Mauritian banks, fees for technical services and other income.

CBDT constitutes ‘working group’ to examine issues arising from Indo-Mauritius DTAA amendment

On 13 June 2016, the CBDT constituted ‘working group’ headed by Joint Secretary (FT&TR-II) to examine consequential issues arising out of amendments to India-Mauritius DTAA and related issues. The working group will comprise of departmental officers and representatives of SEBI, custodians, brokerage firms and fund managers. Further, working group shall submit its report to the CBDT within 3 months, after examining the relevant issues.

Income Tax Appellate Tribunal (ITAT) allows relief to Singapore tax resident company; says treaty benefits can be allowed even if remittance made in subsequent year

The Pune bench of the ITAT has, in case of Imerys Asia Pacific Pvt Ltd, a Singapore tax resident company, allowed benefits of the DTAA between India and Singapore even if the income was remitted during a subsequent year and not during the relevant fiscal year in which it was earned / received. Since fees for technical services were offered to tax on accrual basis in Singapore, the ITAT observed that remittance to Singapore is not mandatory.

CBDT amends Foreign Account Tax Compliance Act (FATCA) rules, revises certain aspects in ‘due-diligence’ procedure

On 20 June 2016, the CBDT issued a notification amending Rules 114F & 114H relating to reporting information under FATCA. The CBDT amends the definition of “passive non-financial entity” to exclude withholding foreign partnership or withholding foreign trust for the purposes of ‘reportable account’ definition under Rule 114F(6). The amended Rule 114H (specifying due diligence procedure) bifurcates between US reportable account and other reportable account with respect to due-diligence procedure for lower value and high vale accounts among pre-existing individual accounts.

The amendments also revise the timeline for review of pre-existing individual accounts and pre-existing entity accounts from 30 June to 31 December 2016. It also revises Form 61B (Statement of Reportable Account) with effect from 1 January 2017.

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Foreign Tax Credit (FTC) rules effective 1 April 2017

On 27 June 2016, the CBDT introduced new FTC rules – FTC will be available to be offset against tax, surcharge and cess payable, including minimum alternate tax (MAT), but not in respect of interest, fees or penalties. Credits will also be allowed in respect of foreign disputed tax subject to compliance with conditions. The new rules will come into force on 1 April 2017.

The new Rule 129(5) states that FTC “shall be the aggregate of the amounts of credit computed separately for each source of income arising from a particular country or specified territory outside India” and any excess FTC, if any, will be ignored. To claim the FTC, taxpayers must furnish a statement of income from the overseas country offered for tax and details of foreign tax in prescribed Form No. 67. Taxpayers should also furnish a certificate or statement specifying the nature of income and the amount of tax deducted.

Rules to determine Fair Market Value (FMV) and income attributable to assets located in India for indirect transfer of assets

Income arising from transfer of share or interest in a company or entity incorporated or registered outside India (Transferred Asset), is taxable in India if such share or interest derives substantial value from assets located in India.

The Transferred Asset is considered to derive its value substantially from assets located India if the FMV of the assets, of the Foreign Company, located in India exceeds Rs.100 Million, and constitutes at least 50% of the FMV of the total assets of the Foreign Company.

On 28 June 2016, the CBDT has now issued the final rules covering the following broad areas:

i. Computation of the FMV of the various classes of assets (Rule 11UB)

ii. Computation of income attributable to assets in India (Rule 11UC)

iii. Information and documents that are required to be furnished by an Indian Concern (Rule 114DB)

ThailandCorporate income tax rates for SMEs

On 21 April 2016, the corporate income tax rates for small and medium enterprises (SMEs) were announced as follows:

For accounting periods beginning on or after 1 January 2015 but not later than 31 December 2016:

Net profit (Baht) Tax rates

0 – 300,000 Nil

Over 300,000 10%

For accounting periods beginning on or after 1 January 2017:

Net profit (Baht) Tax rates

0 – 300,000 Nil

300,001 – 3,000,000 15%

Over 3,000,000 20%

To be eligible for the above tax rates, the SMEs must meet the following conditions:

• Paid-up capital on the last day of any accounting period must not exceed Baht 5 million, and

• Income from the “sale of goods and provision of services” must not exceed Baht 30 million in any accounting period.

Revocation of exemption from indirect taxes for property funds

On 24 May 2016, the Thailand Revenue Department issued regulations to revoke the exemptions from value added tax (VAT), specific business tax (SBT) and stamp duty for property funds that were established under the law governing securities and exchange (i.e. Public Offering Property Fund (type 1 fund), Property Fund for Resolving Financial Institution Problems (type 2 fund), Mutual Fund for Resolving Financial Institution Problems (type 3 fund) and Property and loan fund (type 4 fund)). These regulations will become effective on 24 May 2017.

The exemption from VAT, SBT and stamp duty for the above property funds was provided by the government to help rehabilitate the real estate business and to rectify problems within financial institutions affected by the 1997 economic crisis. It is now considered that such measures have been duly achieved according to the objectives so it is appropriate to repeal the exemption of these indirect taxes for the above property funds.

It is noted that most type 2, 3 and 4 funds have been wound up since 31 August 2015 according to the regulations of the Thailand Securities and Exchange Commission (SEC). However, the SEC has extended the maturity date of some type 2 and 4 funds, such as property funds invested in the qualified master plan project, to 31 August 2035 and 28 February 2066.

Additional specific business tax incentive for IHQ

On 2 June 2016, Royal Decree No. 612 was issued to extend the specific business tax exemption to qualified international headquarters (IHQ) on remuneration received from financial management services provided to associated enterprises. This Royal Decree became retroactively effective from 2 May 2015.

For more details on tax incentives for IHQ, please refer to the following URL: http://www.pwchk.com/webmedia/doc/635677302894780002_aptn_2015_th.pdf

Contact list

Country Partner Telephone Email address

Australia Ken Woo +61 (2) 8266 2948 [email protected]

China Matthew Wong +86 (21) 2323 3052 [email protected]

Hong Kong Florence Yip +852 2289 1833 [email protected]

India Bhavin Shah +91 (22) 6689 1122 [email protected]

Indonesia Margie Margaret +62 (21) 5289 0862 [email protected]

Japan Akemi Kitou +81 (3) 5251 2461 [email protected]

Stuart Porter +81 (3) 5251 2944 [email protected]

Korea Kwang-Soo Kim +82 (0) 10 3370 9319 [email protected]

Malaysia Jennifer Chang +60 (3) 2173 1828 [email protected]

New Zealand Darry Eady +64 (9) 355 8215 [email protected]

Philippines Malou P. Lim +63 (2) 845 2728 [email protected]

Singapore Anuj Kagalwala +65 6236 3822 [email protected]

Taiwan Richard Watanabe +886 (0) 2 27296666 26704 [email protected]

Thailand Orawan Fongasira +66 (2) 344 1302 [email protected]

Vietnam Van Dinh Thi Quynh +84 (4) 3946 2231 [email protected]

This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.

© 2016 PricewaterhouseCoopers Limited. All rights reserved. PwC refers to the Hong Kong member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. HK-20151028-3-C4