Hong Kong Inland Revenue published Advance Ruling Case No. 70 on 15 September 2023, which concerns meeting the economic substance requirement under section 15K of the Inland Revenue Ordinance (IRO). The economic substance requirement must be met under Hong Kong's new Foreign-Sourced Income Exemption (FSIE) regime introduced by the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Ordinance 2022. The new FSIE regime essentially provides that offshore passive income will be deemed to be sourced from Hong Kong and chargeable to profits tax if the income is received in Hong Kong by a constituent entity of an MNE group, unless...