The Hong Kong Inland Revenue Department has published guidance on the new Foreign-sourced Income Exemption (FSIE) regime for passive income, which is pending final approval of the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 by the Legislative Council. As previously reported, the new FSIE regime will allow tax exemptions for specified foreign-sourced passive income received in Hong Kong by relevant MNE entities provided that certain exemption conditions are met. This includes new economic substance requirements, as well as nexus requirements for intellectual property income based on OECD guidelines. The FSIE guidance covers: Specified Foreign-sourced Income Covered Income...