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Stefano Mariani

Stefano Mariani



  • Private Clients
  • Tax

WSG Practice Industries


Hong Kong, China

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.
Areas of Practice

Private Clients | Tax


Salaries Tax Alert: Decision of the Court of First Instance in Dr Leung Ka-Lau v CIR [2021] HKCFI 1117
Deacons, May 2021

Factual background The taxpayer, Dr Leung, was a medical doctor employed by the Hospital Authority (“HA”). Part of the conditions of his employment was that he was required to be ‘on call’ on certain days including Sundays and public holidays. When ‘on call’, he was obligated, among other things, to be within the physical proximity of the hospital, to be ready to render medical services if the need arose, and to abstain from drinking alcohol...

Hong Kong Proposes New Rules Enhancing Deductibility of Foreign Tax
Deacons, April 2021

The Government of Hong Kong gazetted the Inland Revenue (Amendment) (Miscellaneous Provisions) Bill 2021 (the “Bill”) on 19 March which, among other things, seeks to amend the Inland Revenue Ordinance (“IRO”) to expand and clarify the scope of profits tax deductions for foreign taxes...

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