The Taxation on Specified Foreign Sourced Income Bill 2022 was passed by Hong Kong's legislative council on 14 December 2022 and the new foreign-source regime for offshore passive income is now in effect. If received in Hong Kong, passive income, including interest, dividend, disposal gains and income from intellectual property are now deemed Hong Kong-sourced income subject to 16.5 per cent profits tax. Two last-minute amendments were made by the government, removing the exclusion of certain entities from the regime and exempting foreign-source income derived from profit-producing activities, as required under the preferential tax regimes.
News Source：【Alvarez & Marsal 2023/01/09】