31 Oct 2024 Tax update on foreign-sourced income exemption (“FSIE”) regime

Oct 2, 2024

The latest international tax standards necessitate that taxpayers benefiting from preferential tax treatments in any jurisdiction must demonstrate substantial economic presence and establish a clear link between the relevant income and economic activities within that jurisdiction. To align with the international standards, Hong Kong refined its FSIE regime which takes effect from 1 January 2023. The regime was further enhanced to cover foreign-sourced disposal gain on assets other than equity interests with effect from 1 January 2024. In this seminar, we will delve into these legislative changes, their implications and compliance requirements for businesses operating in Hong Kong.

Event highlights

· A recap of the refined FSIE regime

· Compliance requirement, including the filing of Form IR1478

· Practical case sharing

Speakers:

Ingrid Lau, Tax Partner, PwC

Ingrid has been actively involved in handling tax investigation cases, dispute settlement with the Hong Kong tax authority, as well as assisting with IPO processes. She has advised major regional assignments including corporate restructuring and cross-border transactions in APAC and Pillar Two advisory work, and has overseen international M&A projects including due diligence and inbound / outbound investments planning and execution. Her focus areas include real estates, food and consumer products, logistics, and media & telecom sectors. She is also a regular speaker for seminar series organized for listed groups and members of professional bodies in Hong Kong.

Candice Mak – Senior Manager, PwC

Candice is a Senior Tax Manager of PwC Hong Kong with more than 10 years of experience in both the professional and public sectors. At PwC, she has extensive experience in providing corporate tax compliance and business consulting services, including offshore claims, tax treaty benefits, tax planning for cross-border transactions and group restructuring, etc. Candice also served in the Hong Kong Inland Revenue Department (IRD), which has provided her with comprehensive knowledge of the IRD's practices and procedures. This diverse background equips her to effectively resolve clients' tax disputes with the IRD from multiple angles. Candice holds bachelor's degrees in both Professional Accountancy and LLB.