Proposal to refine hong kong’s foreign source income exemption (fsie)

Posted on 02/01/2023

The purpose of the proposal is in response to the EU’s concern over tax exemption for offshore passive income in Hong Kong. To avoid double non taxation of this income, Hong Kong Government propose to treat the following 4 types of passive offshore income as deemed sourced from Hong Kong and chargeable to profits tax under certain circumstances:

1. Interest income

2. Income from intellectual properties

3. Dividends

4. Gain on disposal on shares / equity interest

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