- Ms Yan Yeung, Partner, Tax Services, PwC Hong Kong
- Ms Ivy Chow FCG HKFCG, Director, Corporate Services, PwC Hong Kong
In the past decades, offshore incomes so received by Hong Kong companies were usually non-taxable in Hong Kong. In response to European Union’s concerns on economic substance, Hong Kong has adopted a new regime for foreign source income exemption effective from 1 January 2023. Will Hong Kong’s advantage as an effective place for setting up investment holding companies be undermined by the economic substance requirements under the new regime? What are the implications to corporate structures of MNC groups and also company secretaries in Hong Kong?
In this seminar, two seasoned speakers in corporate tax and company secretarial areas will cover the following items:
- Brief background of economic substance requirements
- Overview of the foreign source income exemption (“FSIE”) regime for four types of offshore income, namely (1) interest, (2) dividends, (3) disposal gains from the sale of equity interests in an entity, and (4) intellectual property income, which came into operation on 1 January 2023
- Possible impacts on the covered taxpayers and the MNC groups
- Suggested actions and next steps to be taken by the covered taxpayers and the company secretaries