Webinar: Latest development of the refined foreign source income exemption (“FSIE”) regime
Event Code : 20221124


The Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 (“the Bill”) was gazetted on 28 October 2022, which introduces refinements to FSIE regime for four types of offshore income, namely (1) interest, (2) dividends, (3) disposal gains from the sale of equity interests, and (4) income from intellectual property expected to take effect from 1 January 2023.

On the same date, the Inland Revenue Department also published an administrative guidance on the refined FSIE regime which includes frequently asked questions, illustrative examples and procedures for applying for a Commissioner’s Opinion on the compliance with the proposed economic substance requirement.

As the refined FSIE regime presents unprecedented and significant changes to Hong Kong’s tax system and complex rules may apply depending on the circumstances of each case, corporations in Hong Kong should keep a close eye on the latest development of the refined FSIE regime. 

In this webinar, the speakers will share with you the latest update of the refined FSIE regime.  Specifically, the webinar will cover the following areas:

  1. Overview of the refined FSIE regime
  2. Highlights of the updates introduced in the Bill
  3. Procedures of application for the Commissioner’s opinion under the refined FSIE regime
  4. Potential impacts of the refined FSIE regime on corporations in Hong Kong
  5. How should taxpayers get prepared before the refined FSIE regime comes into operation?
  6. Q&A


Ms. Yan Yeung, Partner, Tax services, PwC Hong Kong

Yan Yeung is a Partner of PwC Hong Kong’s corporate tax practice. She has over 19 years of experience in providing Hong Kong and international tax compliance and consulting services to local, regional and multinational clients. She has been actively taken part in regional corporate structuring, merger and acquisition, tax due diligence, tax investigation, tax accounting and IPO projects. Yan is also a frequent speaker in tax seminars organised by accountancy and taxation professional bodies in Hong Kong. She is a member of The Hong Kong Institute of Certified Public Accountants and a Chartered Tax Advisor of The Taxation Institute of Hong Kong.


Ms. Joyce Chak, Senior Manager, Tax Controversy Services, PwC Hong Kong

Joyce is a Senior Tax Manager at PwC Hong Kong. Prior to joining PwC Hong Kong, she had been working in the Hong Kong Inland Revenue Department for more than 6 years under the Profits Tax Unit and the Field Audit and Investigation Unit. She has been providing HK tax controversy and business consulting services, including handling tax audit and investigation cases and prolonged profits tax disputes with the HK IRD and has successfully assisted clients in resolving various tax issues, including offshore claim and settling tax disputes with the IRD. She graduated from the University of Hong Kong and is a member of the Hong Kong Institute of Certified Public Accountants.

CPD Hours:
1.5 Hours
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