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Discussion Paper on Refinements to Hong Kong's Foreign Source Income Exemption Regime for Passive Income

18 July 2022

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Proposed Changes

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Hong Kong

Hong Kong's Legislative Council Panel on Financial Affairs has published a discussion paper on Refinements to Hong Kong's Foreign Source Income Exemption (FSIE) Regime for Passive Income. According to the paper, consensus was reached with the Code of Conduct Group (Business Taxation) of the EU in June 2022 on a package of proposed refinements to the FSIE regime with regard to passive income. The refinements are meant to address EU concerns and keep Hong Kong from being blacklisted as a non-cooperative jurisdiction. Details of the refined FSIE regime are provided in the paper as follows: --- Covered income and covered...