概要 《2022年稅務(修訂)(指明外地收入徵稅)條例》(以下簡稱「《修訂條例》」)於今(2023)年1月1日起生效。 在新FSIE制度下,於香港經營行業、專業或業務的跨國企業實體,其在香港所收取之特定海外所得(即利息、股利、處分股權產生之資本利得和智慧財產權收入)皆將被視為香港來源所得,須被徵收香港利得稅(Profits ...
To acknowledge that active income is not covered by the FSIE regime, disposal gains on assets (other than IP) derived from, or are incidental to, the carrying on of a business as a trader would be excluded. Trader means any entity that sells, or offers to sell, property in...
2. Participation exemption (additional pathway for dividends and disposal gains) 3. Nexus requirement (for IP income) Where no exemption applies, double taxation relief is available. For details of the FSIE regime, please refer to oursummary diagram,Hong Kong Tax Analysis Issue H110/2022,Hong...
but an employee can file Form 673, Statement for Claiming Exemption from Withholding on Foreign Earned Income Eligible for the Exclusion(s) Provided by Section 911 with the US employer to claim the exemption from withholding on wages because of the expected foreign earned income exclusion or foreig...
The Hong Kong SAR government proposed to refine Hong Kong’s foreign source income exemption (FSIE) regime for passive income with effect from 1 January 2023. Four types of offshore passive income, namely (1) interest, (2) income from intellectual properties, (3) dividends and (4) disposal...
Last Friday, on 13 October 2023, the legislative bill for the foreign-sourced income exemption (FSIE) regime to extend the scope of disposal gains to cover all types of assets was gazetted.
Tax reforms in recent years have admittedly been pragmatic and responsive to changing economic needs. The exemption of foreign income, the increasing network of tax treaties and hopefully further liberalization of equity ownership requirements, provide not only business and tax planning opportunities but ...
Yes, as a US citizen or resident, you generally must pay US taxes on your worldwide income, including foreign income. However, the Foreign Earned Income Exclusion (FEIE) allows you to exclude a significant amount of your foreign earnings from US taxation—up to $120,000 for 2023.Additionally...
In case of tax exemption or concession enjoyed in the foreign country then the return must be accompanied by A declaration that the foreign country has exempted the foreign income from tax because of substantive business activities carried on by the company in that country; and ...
DESIGNING A U.S. EXEMPTION SYSTEM FOR FOREIGN INCOME WHEN THE TREASURY IS EMPTY Florida Tax ReviewFleming Jr., J. CliftonPeroni, Robert J.Shay, Stephen E.