Stefano Mariani

Partner | Corporate Commercial

stefano.mariani@deacons.com
+852 2825 9314
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"Stefano Mariani is considered a rising star in the tax space, offering advice on contentious and non-contentious matters. A client remarks: 'He is very knowledgeable and practical. He knows what the tax authority is looking for and how the rules and laws may be interpreted.'"

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.

Stefano is a solicitor advocate with higher rights of audience in civil proceedings before the High Court and Court of Final Appeal. He represents clients as an advocate at all stages of civil proceedings.

He is an Adjunct Associate Professor of the Faculty of Law at the University of Hong Kong 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.

More about Stefano Mariani

  • Recognised as an Up and Coming lawyer for Tax: Hong Kong Law (International Firms) (China) in Chambers Asia-Pacific (2021)
  • Recognised as Next Generation Partner for Tax and Trusts in Legal 500 Asia Pacific (2020 – 2021)
  • Recommended Lawyer for Tax and Trust in Legal 500 Asia Pacific (2021)

  • Department of Law of The University of Hong Kong – Adjunct Associate Professor
  • 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)

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

  • ‘A critical assessment of the Hong Kong Inland Revenue Department’s revised Departmental Interpretation and Practice Note No. 28 on the deductibility of foreign tax’ – Asia Pacific Journal of Taxation, 2019, Vol. 23, No. 2
  • ‘The Uneasy Relationship between Permanent Establishments and Section 14 of the Inland Revenue Ordinance’ – Asia Pacific Journal of Taxation, 2019, Vol. 23 No. 1
  • ‘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

"Stefano Mariani is considered a rising star in the tax space, offering advice on contentious and non-contentious matters. A client remarks: 'He is very knowledgeable and practical. He knows what the tax authority is looking for and how the rules and laws may be interpreted.'"

Languages

  • English
  • Italian
  • French
  • German
  • Spanish

Jurisdictions

  • Hong Kong
  • England and Wales
  • Solicitor Advocate

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