Stefano Mariani
Stefano Mariani

Stefano Mariani

Counsel

LOCATION:
Hong Kong
DIRECT:
+852 2825 9314

Stefano Mariani

Counsel

LOCATION:
Hong Kong
DIRECT:
+852 2825 9314


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Stefano heads the tax and trusts practice at Deacons. He has a broad range of advisory and contentious tax experience, ranging from corporate taxation and group reconstructions to personal taxation and trusts and estate planning and management. He advises on all matters of Hong Kong and international tax law, including tax-efficient structuring and restructuring, and tax appeals before the Board of Review and the higher courts. His experience includes cross-border tax planning and Double Taxation Treaty driven tax structuring. 

Stefano further advises on all areas of Hong Kong and international trusts, estate planning, and charities, including the drafting of trusts instruments, restructuring of trusts structures, and trusts dispute resolution.

He is a lecturer in revenue law at Hong Kong University, and a regular contributor to legal and industry publications, notably including the Hong Kong Law Journal, the Asia-Pacific Journal of Taxation, and the Asia-Pacific Tax Bulletin.  He is a co-author of the seminal Encyclopaedia of Hong Kong Taxation, and the textbook Hong Kong Tax Law: Cases and Materials.

  • Acting for a number of high profile clients, including financial institutions and major merchandise retailers, on disputes with the Hong Kong Inland Revenue Department and before the Board of Review;
  • Acting for a high net worth individual in a salaries tax dispute before the Board of Review;
  • Acting for several high-profile Hong Kong families and individuals in relation to their family trusts and business and estate succession plans;
  • Advising a globally prominent university on the establishment of a charitable, tax exempt foundation;
  • Advising a major overseas bank on Hong Kong stamp duty implications arising from a merger of two European funds and representing the same before the District Court;
  • Advising one of the “Big Four” accountancy firms on the establishment of a Hong Kong trust for a major institutional client; and
  • Advising several European funds, including both private funds and SFC authorised funds, on the availability of tax incentives and exemptions in Hong Kong.

Membership/Appointments

  • Hong Kong Trustees’ Association – Honorary Secretary
  • Lincoln’s Inn
  • Taxation Institute of Hong Kong
  • Asian Institute of International Financial Law – Honorary Fellow
  • Trust and Estate Practitioner
  • Revenue Bar Association
  • International Fiscal Association (Hong Kong Branch)

Publications/Articles

Stefano has authored and co-authored a wide range of articles and books, notably:

Books

Hong Kong tax law: cases and materials (with Prof. Wilson Chow), LexisNexis Butterworths, ongoing: 2017 –

Encyclopaedia of Hong Kong Taxation (contributing author and editor, with Prof. Wilson Chow and Susan Leung), LexisNexis Butterworths, ongoing: 2016 –

Articles

‘On the source of interest in Hong Kong’ – Asia Pacific Tax Bulletin, forthcoming

‘Source, residence, and the future of Hong Kong tax’ – Asia Pacific Journal of Taxation, 2017, Vol. 21, No. 2

‘A critical analysis of the Hong Kong stamp duty implications of company amalgamations and the repurchase by a company of its own shares’ – Hong Kong Law Journal, 2017, Vol. 47, Part 2 (forthcoming)

‘A critical assessment of the Inland Revenue Department’s revised and updated guidance on the tax consequences of company amalgamations’,  Asia Pacific Journal of Taxation, 2017, Vol. 21, No. 1 (forthcoming)

Ho Kwok Tai v Collector of Stamp Revenue [2016] 5 HKLRD 713 – analysis and implications’, Hong Kong Law Journal, 2017, Vol. 47, Part 1

‘A critical and comparative assessment of the utilisation of losses in company amalgamations’, Asia Pacific Journal of Taxation, 2016, Vol. 20, No. 1

‘On the source and taxation of royalties in Hong Kong’ – Asia Pacific Tax Bulletin, 2016, Vol.22, No.3

‘Advance Rulings – Decline and Fall?’ – Tax Notes International, 2016, Vol. 81, No. 2

‘The Taxation of Trusts in Hong Kong’ – Asia Pacific Tax Bulletin, 2015, Vol. 21, No. 6

‘Hong Kong Stamp Duty Relief for Foreign Law Mergers’– Hong Kong Lawyer,October 2015

‘The Taxation of Grants, Subsidies, and Similar Financial Assistance in Hong Kong’ – Asia Pacific Journal of Taxation, 2015, Vol. 18, No.2

‘The Source of Dividends in Hong Kong Tax Law’ – Asia Pacific Tax Bulletin, 2015, Vol. 21, No. 3

‘Traditional Chinese Religion trusts in Hong Kong’ – Trust & Trustees, June 2015, 21(5)

‘Jersey and the Public International Law Dimensions of Sovereignty’ – The Jersey and Guernsey Law Review, 2013, Vol. 17 Issue 1

Others

Tutor and lecturer in advocacy and revenue law at Hong Kong University.

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