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  1. www.pwccn.com › en › servicesHong Kong’s foreign-sourced income exemption (FSIE) ...

    2023年11月29日 · Hong Kong should remain an effective investment holding platform under the refined foreign source income exemption (FSIE) regime Hong Kong’s FSIE regime, which takes effect from 1 January 2023, has been further refined to cover foreign-sourced disposal gains on assets other than equity interests with effect from 1 January 2024.

  2. www.ird.gov.hk › eng › taxIRD : Foreign-sourced Income Exemption

    With a view to supporting international efforts in combating cross-border tax evasion and preventing double non-taxation, Hong Kong committed to amending its Foreign Source Income Exemption (FSIE) regime for passive income in accordance with the Guidance on FSIE regimes promulgated by the European Union (EU).

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  4. www.hkwj-taxlaw.hk › fsieA Guide to The Foreign Sourced Income Exemption Regime ...

    • Who Falls Under The FSIE Regime?
    • What Does FSIE Cover?
    • Exemption Conditions
    • Advance Ruling & The FSIE
    • HKWJ Tax Law Can Help

    Members of Multinational Enterprise Entity (MNE) groups (i.e. MNE entities) carrying on a trade, profession or business in Hong Kong are subject to the new FSIE regime (“covered taxpayer”), unless they can meet the exemption conditions. This means the FSIE regime does not apply to: 1. Standalone local enterprises without offshore operation 2. Compa...

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    The existing territorial source regime will continue to be applied in Hong Kong. Nevertheless, the following four types of foreign-sourced passive income (“covered income”) received in Hong Kong by a covered taxpayer are deemed to be sourced from Hong Kong under the FSIE regime and liable to Hong Kong Profits Tax at the standard rate of 15%/16.5% o...

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    The four types of foreign-sourced passive income could be excluded from Hong Kong Profits Tax under the FSIE regime if the conditions under the economic substance requirement (ESR), participation exemption or nexus exemption can be met, which are summarised as follows: The economic substance requirement applies to interests, dividends, and share di...

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    In order to (a) know in advance whether the ESR can be met and/or whether the income is subject to Hong Kong profits tax under the FSIE regime and (b) reduce the compliance burden, taxpayers can apply for an advance rulingwith the IRD. An advance ruling is valid for up to five years of assessment. In addition, the ruling is legally binding. Applica...

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    Does the FSIE regime impact your company’s tax liability on passive income? Should you take any actions, such as strengthening your economic substance in Hong Kong? Will it help to modify your current business and investment structure? Our experienced tax lawyers at HKWJ Tax Law & Partners are here to answer your questions, provide tailored tax adv...

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  5. robertsonshk.com › en › newsKey Takeaways From The New Foreign-Sourced Income Exemption ...

    Key takeaways. New regime only applies to MNE entities. Individuals and standalone local companies are not affected. Hong Kong continues to adopt the territorial source principle of taxation. New FSIE regime is not intended to change the low-tax regime in Hong Kong.

  6. www.ird.gov.hk › eng › faqFSIE Regime - Frequently Asked Questions - Inland Revenue ...

    No. Borrowing money for financing its equity investment and earning incidental income (e.g. exchange gains) from such borrowing does not disqualify the taxpayer from being a pure equity-holding entity.

  7. www.hkicpa.org.hk › - › mediaRefined foreign source income exemption (FSIE) regime

    The foreign-sourced dividend was regarded as received in Hong Kong when the movable property was bought into Hong Kong. The taxable amount of the dividend was that applied to acquire the movable property (i.e., HK$5 million), not the value at the time when the property was brought into Hong Kong (i.e., HK$7 million).

  8. research.hktdc.com › en › articleFinancial Services Industry in Hong Kong - HKTDC Research

    2023年12月15日 · As of September 2023, there were 2,927 SFC-authorised collective investment schemes, including 2,339 unit trusts and mutual funds, 314 investment-linked assurance schemes, 249 pension or MPF-related funds, 11 REITs and 14 paper gold schemes.

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