Time to get prepared for the Refined Foreign-sourced Income Exemption Regime (FSIE)

Event Details

The Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 on Hong Kong's foreign-sourced income exemption (FSIE) regime was introduced to the Legislative Council in early November 2022 subsequent to the prolonged negotiation with the European Union (EU) and the consultation exercise with stakeholders. The Bill proposes that specified foreign-sourced income received in Hong Kong, including interest, dividend, disposal gain on equity interests and income from intellectual properties, would be deemed taxable in Hong Kong unless certain conditions are met. Subject to the legislative procedures, the new regime will be effective from 1 January 2023. The Inland Revenue Department has also published some guidelines on the proposed FSIE regime on its website to facilitate taxpayers' understanding of the regime and practical matters.

Join our webinar, where the experts from Deloitte China will talk about the latest development and practices facing the refined FSIE regime; and help you understand any significant changes or clarifications of the rules as compared to the draft rules published back in July 2022 during the public consultation so as to get prepared for the new regime on how it may impact your corporations.

Remarks:

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Speakers

Kwan Yu

Tax Partner, International Tax Services at Deloitte China

Yiu-Hong Chung

Tax Director, International Tax Services of Deloitte China

Peter Guang Chen

Partner at Yang Chan & Jamison LLP

Kwan Yu is a Tax Partner with Deloitte China’s International & M&A Tax Services based in Hong Kong. He is also a member of the Asia Pacific International Core of Excellence (AP ICE) which is a core group of senior tax professionals that provides international tax services to Asia Pacific based companies investing abroad as well as multinational companies investing in the region.

Prior to joining the Deloitte Hong Kong office, Kwan worked in the Business Tax Services team of the Deloitte Greater Washington and New York offices.

Kwan has over 20 years of international tax experience in the U.S. and Hong Kong providing tax advisory services to multinational clients including cross-border investment, restructuring and acquisition planning, Value Chain Alignment (“VCA”), corporate reorganizations, and various tax accounting and compliance matters.

Kwan serves clients in a wide variety of industries, including consumer products, retail, manufacturing, high-tech and financial services.

Kwan graduated from the University of Virginia with a Master of Science degree in Accounting – Tax and a Bachelor of Science degree in Commerce with a concentration in Accounting. Kwan is a member of the AICPA and a CPA licensed in the State of Virgina.

Yiu-Hong Chung is a Tax Director with Deloitte China’s International & M&A Tax Services based in Hong Kong.

Yiu-Hong joined Deloitte since 2007. During his career with Deloitte, Yiu Hong worked in the China Tax Desk at Deloitte New York office and provided technical and practical solutions to US based MNCs for their investments, operations and exits from China and Hong Kong. He also worked in Deloitte China's National Technical Center in Shanghai, where he reviewed and provided comments to draft circulars to be issued by the State Taxation Administration of China and contributed to technical writings of the Deloitte China firm.

Yiu-Hong provides tax advice to multinational corporate clients who wish to invest in China and Hong Kong, including structuring and acquisition issues, supply chain planning, cross-border transfer pricing strategies, corporate reorganizations, and tax/regulatory compliance matters.

Yiu-Hong holds a B.A. from the Chinese University of Hong Kong. He also studied in the University of Texas at Austin through an exchange program. Yiu-Hong is a member of The Hong Kong Institute of Certified Public Accountants (HKICPA).

Peter Guang Chen is both a certified public accountant and an attorney with more than 20 years of experience, and who is practicing in Hong Kong. Peter has advised multinational companies on their investment structuring, regulatory, and business issues; mergers, acquisitions, reorganizations in U.S., China and the Asia Pacific region; He has represented both companies and individuals to resolve tax disputes with tax authorities in the US and China. Also, Peter has advised US, China and Hong Kong high net worth individuals on the structuring of trusts, foundations in the income tax and estate planning context, as well as advising them on China and international tax issues. Previously, Peter was with a major economic consulting firm and also was a tax partner at Deloitte, where he was responsible for the China Desk in NYC. He is a frequent speaker and writer on international tax issues.

Peter is admitted to practice as attorney in United States (New York & New Jersey), United States Tax Court, Federal District Court (SDNY, EDNY, NJ). He is also licensed as CPA in New York and New Jersey. Peter is also admitted to practice law in Hong Kong as a solicitor.

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