In an increasingly challenging environment, we, as professional accountants, can explore more opportunities to offer a diverse range of tax compliance and advisory services to our clients.

- Foreign-Sourced Income Exemption (“FSIE”) Reform

- Offshore Claim on Interest Income

- Latest Preferential Tax Regimes on Funds, Single Family Offices and Carried Interest

- BEPS 2.0 in Hong Kong- Hong Kong Tax Residency Certificate - Corporate and PRC Beneficial Ownership Requirement

- Hong Kong Tax Residency Certificate - Individual- Field Audit and Investigation Case Sharing

FSIE has become a tax policy that many of taxpayers need to confront. In 2024, the Inland Revenue Ordinance expanded the scope of passive income covered under the FSIE regime. Engaging in tax planning at an early stage can assist taxpayers in mitigating their tax exposures.

On the other hand, in the recently released minutes of the 2023 annual meeting between the IRD and the HKICPA, the IRD clarified its stance on defining a "simple loan of money" and a "money-lending" business. It stated that the "provision of credit test" would assess the source of interest income from a "simple loan," while the "operation test" would apply in other scenarios. Typically, an "intra-group financing" business, which does not usually lend to the general public, would not be classified as a "money-lending" business.

Furthermore, during the 2024/25 Budget speech, the Financial Secretary unveiled initiatives aimed at strengthening the preferential tax frameworks for funds, single family offices, and carried interest. The strategy involves reviewing the extent of tax exemptions, expanding the categories of qualifying transactions, and increasing the adaptability for incidental transactions. The enhancements to the three frameworks are expected to strengthen Hong Kong's standing as a premier global asset management hub

On 15 January 2025, the OECD published additional materials on Pillar Two's GloBE rules under BEPS 2.0, including administrative guidance on transition rules for deferred tax assets and a list of qualified jurisdictions with an updated Q&A. It also released four GIR-related documents: an updated template with commentary, completion guidance, an MCAA for filing/exchange, and an updated XML schema with a user guide.

Hong Kong Tax Residency Certificate (TRC) - Corporate and PRC Beneficial Ownership Requirement [2018 Bulletin No.9] has become a popular topic for outbound investment and export business of PRC enterprises. While the requirements for TRC has been relaxed in Hong Kong, the PRC State Administration Taxation has been actively carrying out investigation on eligibility of reduced dividend withholding tax under 2018 Bulletin No.9. Many taxpayers suffer from penalty and surcharge payment for non-compliance with 2018 Bulletin No.9.

Hong Kong TRC – Individual has been a common topic given the increasing interest of Mainland China residents obtaining the residency in Hong Kong. However, many of them have misunderstood that Hong Kong resident equals to Hong Kong tax resident. We will share our experience in obtaining the TRC and the importance of the TRC to their Mainland China Tax liability.

Field Audit and Investigation cases are extremely common in Hong Kong. We will share 1-2 recent case studies to explain efficient handling of Tax audit cases, and potential criminal offences published in the IRD’s website. 

Accountants seeking to diversify and expand their taxation service offerings are the intended participants of this seminar.

*Light refreshments will be available for those attending in person.*

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