Hong Kong Tax Ruling: Substance Requirements for Foreign-Sourced Income Exemption
On 15 September 2023, the Hong Kong Inland Revenue released Advance Ruling Case No. 70, addressing the economic substance requirement outlined in section 15K of the Inland Revenue Ordinance (IRO) under Hong Kong’s new Foreign-Sourced Income Exemption (FSIE) regime. This regime, established by the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Ordinance 2022, deems…
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