Hong Kong Foreign-Sourced Income Exemption Review

Hong Kong’s FSIE regime can affect multinational entities receiving specified foreign-sourced income in Hong Kong. Describing income as offshore does not alone establish exemption.

Match each income stream to the correct rule

We coordinate the analysis with a Hong Kong tax professional. Interest, dividends, intellectual-property income and disposal gains are identified separately. Economic substance, participation, nexus and relevant intra-group relief conditions are tested only for the income to which they apply; one exception is not treated as a universal exemption.

Information and documents

Provide group and ownership charts, accounts, income and remittance records, asset details and evidence of activities. The deliverable is an exposure assessment, evidence-gap schedule and agreed recommendations. Tax returns, advance rulings, restructuring and implementation are separately scoped, with no exemption or ruling outcome promised.

Scope, fees and completion

Coutts Consultants coordinates the records and the appropriate accounting professional, with unresolved items referred for management approval. The quotation specifies periods, transaction volumes, outputs and any included submissions. Audit, additional tax advice and reconstruction of incomplete records are separately scoped where needed; management remains responsible for the information, approvals and payments.