An overview of the new Foreign-Sourced Income Exemption regime in Hong Kong

16 March 2023
10:00 - 10:45 (GMT+8)
 -  Online
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To address the European Union’s concerns about the risks of double non-taxation under Hong Kong’s offshore regime for passive income, Hong Kong has amended its tax legislation to introduce a new Foreign Source Income Exemption ("FSIE") regime for foreign-sourced interest, dividends, disposal gains from the sale of equity interests and intellectual property income.

Under the FSIE regime, the above-mentioned foreign-sourced passive income may be deemed to be sourced from Hong Kong and chargeable to profits tax, unless certain requirements are met (i.e. economic substance, participation exemption and nexus requirements). In addition, the FSIE regime provides relief against double taxation in respect of the relevant income. The FSIE has come into operation on 1 January 2023.

The purpose of this webinar is to give an overview of the new FSIE regime, explain the potential impact to businesses and discuss the administrative guidance issued by the Hong Kong Inland Revenue Department and suggested action plan to be taken in order to mitigate the tax impact.


Headshot of Samuel Fung

Samuel Fung - Senior Tax Manager, Accounting & Tax, TMF Hong Kong

Samuel is a Senior Tax Manager based in Hong Kong. He has more than 15 years of professional experience. Prior to joining TMF Group, Samuel worked at the Hong Kong Inland Revenue Department, international CPA firms and commercial sectors. Samuel is experienced in providing Hong Kong tax advisory services and well-versed in handling tax audits conducted by tax authorities. He has proven track records of assisting companies ranging from local SMEs to multi-national corporates in navigating through the ever evolving and increasingly complex regulatory and compliance environments.

Headshot of Alexis Ku

Alexis Ku - Global Business Development Manager, TMF Hong Kong

Alexis Ku joined TMF Group as a Global Business Development Manager, generating new business from global markets and optimising market share, revenue and profit. She has over five years of experience in business development, account management and client service excellence. Before joining TMF Group, Alexis worked as Senior Consultant at Tricor, where she was responsible for establishing new business and serving key accounts of Tricor Staffing Solutions (“TSS”). She has experience in serving companies at different levels, from local SMEs to multi-national corporates.

Foreign-Sourced Income Exemption regime in Hong Kong