Hong Kong: proposal to better define foreign source income exemption (FSIE)

The objective of the proposal is to address EU concerns regarding the tax exemption of passive offshore income in Hong Kong. In order to avoid double non-taxation of such income, the Hong Kong Government proposes to treat the following 4 types of passive offshore income as deemed to arise in Hong Kong and taxable for income tax purposes in certain circumstances:
1. Interest income
2. Income from intellectual property
3. Dividends
4. Capital gains on disposal of shares / holdings

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