Hong Kong’s Refined Foreign-Sourced Income Exemption Regime to take effect from 1 January 2023 [只提供英文版本]
2022年12月14日
The draft legislation for implementing the refined Foreign-Sourced Income Exemption (“FSIE”) regime i.e. the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 (“Amendment Bill”) was gazetted on 28 October 2022. Under the refined FSIE regime, four types of offshore passive income, namely (1) interest income, (2) income from intellectual properties, (3) dividend and (4) disposal gain on shares will be deemed to be sourced from Hong Kong and chargeable to profits tax under certain circumstances. The proposed refined FSIE regime is expected to take effect from 1 January 2023 with no grandfathering arrangement.