As a response to the European Union's concerns about Hong Kong's offshore regime for passive income, the HKSAR Government has recently proposed a revised foreign source income exemption (FSIE) regime for passive income which is expected to take effect on 1 January 2023 with no grandfathering arrangement. The HKSAR Government invited certain relevant parties and stakeholders to respond to a consultation paper by 15 July 2022.
MNCs expecting to accrue / receive Hong Kong sourced offshore passive income (i.e. interest, income from intellectual properties, dividends and disposal gains in relation to shares or equity interest) would be covered under the FSIE regime. This would be one of the most significant changes to the long-established territorial principles of the Hong Kong tax system.
In this webinar, tax experts at KPMG will provide an overview of the proposed FSIE regime, the implications thereof, as well as their views and some practical considerations regarding the next steps.
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