HK’s New Foreign-sourced Income Exemption (FSIE) Regime

Hong Kong’s new Foreign-sourced Income Exemption (FSIE) Regime

Further to the consultation launched by the Hong Kong SAR Government on the proposed FSIE regime in June 2022, the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 (the Bill) was gazetted on 28 October 2022. The new FSIE regime would take place with effect from 1 January 2023.  

Corporate groups operating in multiple jurisdictions are expected to accrue/receive the specified foreign-sourced income in Hong Kong (i.e. interest, intellectual property income, dividends and disposal gains derived from the sale of an equity interest) that would be covered by the FSIE regime where tax exemption would continue to be available if certain conditions are met.  

The Bill is more than 70 pages long, making it one of the most significant amendments to the Inland Revenue Ordinance (IRO). As part of a follow up to the webinar held in August 2022, KPMG speakers will provide an update and an overview of the Bill, together with the administrative guidance that the IRD has published. They will also share their views on practical considerations to prepare yourself to embrace the new era of Hong Kong taxation.

Speakers:

Anita Tsang is Director, Tax Policy and Knowledge Management of KPMG China who has over 15 years of experience in Hong Kong and international taxation. Before joining KPMG as a Tax Technical Director, Anita worked in the Tax Services Team at other two international tax practices.

Eugene Yeung is a tax partner of KPMG China who has over 20 years of professional tax experience with a unique mix of exposures.  He has spent more than a decade of time with global tax consulting practices in Hong Kong advising local, Chinese and multinational clients on a wide range of corporate tax and company law matters.