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Which Entities Are Excluded from Hong Kong’s FSIE Regime?
Episode 2066
Published 1 month, 2 weeks ago
Description
Which Entities Are Excluded from Hong Kong’s FSIE Regime?
Yes. Certain entities are excluded from the Hong Kong FSIE regime for specified types of foreign-sourced income.
The exclusion can apply to foreign-sourced interest, dividends, and non-IP disposal gains accruing to:
- Regulated financial entities, such as authorized insurers, banks, or licensed securities dealers; or
- Traders, where the relevant income is derived from or incidental to their regulated or trading business.
Key takeaway: The FSIE regime does not apply uniformly to every MNE entity. Where a regulated financial entity or qualifying trader falls within the relevant exclusion, specified foreign-sourced income may remain outside the FSIE regime.