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Hong Kong Updates Guidance on Foreign-Sourced Income Exemption Based on Pending Amendments

16 October 2023

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Proposed Changes

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Hong Kong

The Hong Kong Inland Revenue Department has published updated guidance on the new Foreign-Sourced Income Exemption (FSIE) regime that takes into account the pending refinements to the regime that will be introduced by the Inland Revenue (Amendment) (Taxation on Foreign-sourced Disposal Gains) Bill 2023 (previous coverage). The relevant updates for the refinements are highlighted with orange boxes in the guidance. Some of the main refinements include: An exclusion relating to traders; Intra-group transfer relief for disposal gain; and Commissioner's opinion on compliance with the economic substance requirement in respect of disposal gains on expanded scope of assets. --- Exclusion Relating...