Hong Kong SAR

New legislation enacted

The following pieces of legislation were enacted in the past 12 months:

• The Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance 2023 was gazetted on 19 May 2023, which introduces a 0% concessionary profits tax rate on assessable profits earned from qualifying transactions and incidental transactions (the latter being subject to a 5% threshold) for an eligible family-owned investment holding vehicle (FIHV) managed by an eligible single family office (ESF Office) in Hong Kong. The tax concession will apply retrospectively to any year of assessment commencing on or after 1 April 2022.
• The Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Ordinance 2022 was gazetted on 23 December 2022. With effect from 1 January 2023, four types of offshore income, namely (i) interest, (ii) dividends, (iii) disposal gains derived from the sale of equity interests (disposal gains), and (iv) income from intellectual properties (IPs), are deemed to be sourced from Hong Kong SAR and chargeable to profits tax under certain circumstances.
• The Inland Revenue (Amendment) (Tax Concessions for Certain Shipping-related Activities) Ordinance 2022 was gazetted on 22 July 2022, which introduces a profits tax exemption or a concessionary profits tax rate of 0% or 8.25% for a qualifying shipping commercial principal carrying out qualifying ship agency, ship management, or ship broking activities. The concessionary tax treatments apply to sums received or accrued on or after 1 April 2022.