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Hong Kong Notes Continued Refinement of Regime Against Cross-Border Tax Avoidance for Foreign-Source Capital Gains

|Proposed Changes|Hong Kong
Hong Kong

The Hong Kong Inland Revenue Department has issued a release on the government's continued refinement of the regime against cross-border tax avoidance, the Foreign-Sourced Income Exemption (FSIE) regime. The new FSIE regime, which entered into force on 1 January 2023, allows tax exemptions for specified foreign-sourced passive income received in Hong Kong by relevant MNE entities provided that certain exemption conditions are met, including economic substance requirements. With respect to ca…

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