Post-acquisition integration - what you need to do? Hong Kong

Part of a comparative survey based on selected papers presented at the Baker & McKenzie 24th Annual Asia-Pacific Tax Conference held in Kuala Lumpur, Malaysia on 13 and 14 November 2008. The scenario assumed is where two foreign groups merge overseas and this is followed by: a local merger; a local acquisition of assets; or the retention of the two separate local operating units. Questions considered are: 1. Are there alternative approaches to local country consolidation, including the trade-offs among (i) tax efficiency, (ii) speed and (iii) fees/costs? 2. Are there opportunities to step up the basis of assets? 3. Are there any leveraging opportunities that could generate tax-efficient interest deductions? 4. What are the capital gains tax and stamp tax issues and potential planning relating to transfers of shares to position the subsidiaries for the ultimate consolidation? 5. How can the tax losses of one entity be preserved? 6. What opportunities exist to restructure intellectual property rights so as to generate tax efficiencies? 7. What tax elections, if any, need to be made? 8. If the entities have different tax years, can this be changed? 9. Are there any obvious tax-related employment issues that arise? 10. Are there any other obvious tax planning opportunities?