Latest from tax alerts
- February 2023: The FSIE regime will be expanded to cover capital gains for the Hong Kong SAR to get off from the EU grey list for tax purposes
- December 2022: The draft legislation on the foreign-sourced income exemption regime was passed
- December 2022: Latest updates on the foreign-sourced income exemption regime in Hong Kong SAR
- November 2022: A closer look at the new foreign-sourced income exemption regime in Hong Kong SAR
- November 2022: The 10 points to note for applying for the Commissioner’s Opinion under FSIE regime
- October 2022: The draft legislation of the FSIE regime in Hong Kong SAR is out
- September 2022: “Commissioner’s Opinion” as an interim measure to confirm compliance with the economic substance requirements under the revised FSIE regime
- June 2022: The HKSAR Government’s proposed changes to the offshore regime for passive income in Hong Kong SAR
What is FSIE?
^ Excludes interest, dividend or equity disposal gain derived by
(1) regulated financial entities from a regulated business; or
(2) entities eligible for preferential tax regimes in Hong Kong (SAR)
It is expected that non-equity capital gains will be included as specified foreign-sourced income effective from 1 January 2024.
* Adequate number of qualified employees in Hong Kong (SAR) to carry out specified economic activities
* Adequate amount of operating expenditures in Hong Kong (SAR) for carrying out specified economic activities
* Reduced substantial activities test for “pure equity holding entity” (PEHE)
* Permittable outsourcing of the relevant activities conducted in Hong Kong (SAR)
Questions you may now have?
- Are you covered?
- Do you earn the subject income?
- Do any of the exemptions apply?
- What options are there to minimise the impact?
- How do you manage any risks?
How can we help?
- Planning and assessment
- Implementation
- On-going compliance
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