Exhibit 8.3
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Resident Hong Kong Partners
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Davis Polk & Wardwell Hong Kong Solicitors The Hong Kong Club Building 3A Chater Road Hong Kong | 852 2533 3300 tel 852 2533 3388 fax | William F. Barron* Bonnie Chan* Karen Chan † Paul K. Y. Chow* † James C. Lin* | Gerhard Radtke* Martin Rogers † Patrick S. Sinclair* Miranda So* James Wadham † | |||||
Hong Kong Solicitors * Also Admitted in New York † Also Admitted in England and Wales |
[ ], 2018
CNFinance Holdings Limited
44/F, Tower G, No. 16 Zhujiang Dong Road
Tianhe District, Guangzhou City, Guangdong Province 510620
People’s Republic of China
Ladies and Gentlemen:
We are acting as United States counsel to CNFinance Holdings Limited (the “Company”) in connection with the preparation of the Registration Statement on FormF-1 (the “Registration Statement”) and the related Prospectus (the “Prospectus”) filed with the United States Securities and Exchange Commission (FileNo. 333-226126) by the Company for the purpose of registering under the United States Securities Act of 1933 (the “Act”) the Company’s ADSs.
We, as your counsel, have examined such matters of fact and law as we have deemed necessary or advisable for the purpose of rendering this opinion.
We hereby confirm that our opinion as to the material U.S. federal income tax consequences to U.S. Holders of an investment in ADSs is set forth in full under the caption “Taxation – Material U.S. Federal Income Tax Considerations” in the Prospectus.
We are members of the Bar of the State of New York and the foregoing opinion is limited to the laws of the State of New York and the federal laws of the United States.
We hereby consent to the use of our name under the captions “Taxation – Material U.S. Federal Income Tax Considerations” and “Legal Matters” in the Prospectus included in the Registration Statement and to the filing, as an exhibit to the Registration, of this letter. In giving this consent we do not admit that we come within the category of persons whose consent is required under Section 7 of the Act.
Very truly yours,