Hong Kong introduces bill to refine its foreign source income exemption regime

The Hong Kong Government introduced a bill on the proposed refinement of the foreign source income exemption (FSIE) regime (the Bill) which is expected to be effective from 1 January 2023.

This Alert highlights the key features of the Bill, with specific reference to the administrative guidance published by the Hong Kong Tax Authority regarding the FSIE regime.

Multinational enterprises (MNEs) should review their Hong Kong holding, financing and intellectual property (IP) structures to assess the …