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Proposed refined foreign source income exemption regime (FSIE regime) - Part two
In this second part of a two-part series, we discuss our views that (i) funds as a collective investment scheme should not be subject to the proposed refined FSIE regime; (ii) in-scope offshore passive income be precisely defined; (iii) taxpayers be assured that so long as all the relevant activities, however minimal, are undertaken in Hong Kong, the economic substance requirement should be considered satisfied; (iv) the source rules for determining disposal gains that are capital in nature be specifically laid down; and (v) a supplementary form to the tax return be introduced for taxpayers’ ease of compliance with the proposed refined FSIE regime.
Please contact your tax executives if you need assistance or have any questions on the proposed refined FSIE regime.
Download this Hong Kong Tax Alert（繁體中文）
Download this Hong Kong Tax Alert（简体中文）