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Proposed refined foreign source income exemption regime (FSIE regime) – Part one
In this first part of a two-part series, we discuss our views on how the terms “received in Hong Kong” and “pure equity holding company” should be defined and interpreted and the relevance of a certificate of residence issued for the purpose of a comprehensive avoidance of double taxation arrangement to the proposed refined FSIE regime.
Please contact your tax executives if you need assistance or have any questions 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）