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Proposed foreign-source income exemption (FSIE) regime
Detailed analysis on the amendment bill and IRD’s administrative guidance.
As reported in our recent tax alert, the HKSAR government (the government) gazetted an amendment bill introducing a proposed refined FSIE regime on 28 October 2022 (the Bill). On the same date, the Inland Revenue Department (IRD) also published on its website detailed administrative guidance with frequently asked questions and illustrative examples to assist taxpayers to understand the proposed refined FSIE regime.
The Bill was tabled to the Legislative Council on 2 November 2022 and committee stage amendments were subsequently proposed in response to the European Union’s latest comments. A Bills Committee was formed to scrutinize the Bill. Clients who have any views or comments on the Bill can relate the same to their tax professionals who will convey their thoughts to the Government in an appropriate manner.
This alert explains in more details the key characteristics and requirements of the proposed refined FSIE regime and IRD’s interpretation and views on the relevant requirements, and our comments on the proposed refined FSIE regime.
Download this Hong Kong Tax Alert（繁體中文）
Download this Hong Kong Tax Alert（简体中文）