With an advance ruling, you can confidently plan their transactions with the assurance that the tax treatment has been agreed in advance and to avoid tax disputes.
Does the new FSIE regime impact your company’s tax liability on passive income? Should you take any actions, such as strengthening your economic substance in Hong Kong? Will it help to modify your current business and investment structure?
It is sometimes argued that a company incorporated under HK Law (“HK Co”) will (a) automatically be regarded as a Hong Kong tax resident; and (b) only be subject to corporate tax in Hong Kong but not in other tax jurisdictions. However, one has to be well aware that if HK Co lacks (has insufficient) ‘tax […]
Today (26 October 2022), the Financial Services and The Treasury Bureau of Hong Kong conducted
a briefing session about the latest development of the FSIE Regime, including certain proposed
amendments to the provisions.
