The bill on the refinement of the foreign source income exemption (FSIE) regime (the Bill) was passed in its current form on 14 December 2022 and will be effective from 1 January 2023.The Hong Kong Government has further clarified certain provisions during the legislative process, including the determination of income qualifying as “received in Hong Kong,” qualification of a “pure equity-holding entity,” and applicable tax rate for the “subject to tax” test.Multinational enterprises (MNEs) should review their Hong Kong holding, financing and intellectual property (IP) structures to assess the tax implications.Executive summaryOn 14 December 2022, the Inland Revenue (Amendment) (Taxation...