For instance, disposal gains on overseas listed securities derived by entities carrying on a securities trading business would be subject to the current FSIE regime. With the exclusion of trader under the refined regime, such offshore disposal gains would be excluded from the FSIE re...
1. Economic substance requirement (for interest, dividends and disposal gains) 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, ...
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...
In this guide, you will learn about the tax treatment of foreign-sourced income in Singapore. We will help you understand the scope of the foreign-sourced income exemption (FSIE) scheme under Sections 13 (7A) to 13 (11) of the Income Tax Act (ITA) of Singapore. Singapore has a progress...
The draft legislation that refines Hong Kong's FSIE regime by expanding the scope of foreign-sourced disposal gains (the Bill1) was passed by the Legislative Council yesterday (i.e., 29 November 2023).