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. Please refer to the Financial Services Tax News Flash for a summary of the issues and our comments on them.