Update on Hong Kong’s Foreign Source Income Exemption

[Marzio]

Under the updated FSIE regime, offshore in-scope 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[1] group (“covered taxpayer”) irrespective of its revenue⁠ or asset size; and
  
• The recipient entity fails to meet the economic substance requirement for⁤ in-scope, non IP, offshore income, or fails to comply with the nexus approach for IP⁣ income.
  

https://www.sannegroup.com/our-thin...-hong-kong-s-foreign-source-income-exemption/
Who would continue to do business in HK after Xi wanting HK to⁢ become China and with those restrictions on FSI?

 

[JackAlabama]

What is︀ really disturbing is HK being closed off for so long and these ever tightening rules︁ there made me exit HK for good.
If HK became China or nah never really︂ bothered me tho and I hoped they would apply one or the other "openness" of︃ USA regarding companies at least.

 

[Marzio]

Did you go for DXB?

 

[JackAlabama]

Yes. And increased US exposure‌ as well. A good working combo.

 

[backpacker]

Sorry, but︀ this is old news. A thread already exists over here -> Hong Kong (Passive) Foreign︁ Source Income Exemption to end 1 Jan 2023 .

 

[Marzio]

I forgot that i even commented in that thread LOL