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🇭🇰 Hong Kong: why "foreign dividends are tax-free" isn't always true anymore
There's a popular myth: in Hong Kong, foreign dividends are never taxed. That used to be true. But since 2023, the FSIE regime changed the picture.
❗️ How it works now:
Hong Kong is still territorial — only Hong Kong-sourced income is taxed. But FSIE introduced an important exception for passive income (interest, dividends, IP income, disposal gains) at companies that are part of multinational groups.
If such income is "received in Hong Kong," it's treated as local and taxed — unless one of the exemption conditions is met.
To keep foreign dividends tax-free, you need one of two things:
Either economic substance in Hong Kong — real staff, premises, and expenses matching the company's functions. Or the participation requirement — holding at least 5% for at least 12 months, provided the income is taxed abroad at a rate of no less than 15%.
⭐️Key nuances:
The regime only applies to members of multinational groups — standalone local companies fall outside it. If neither condition is met, dividends are taxed, but foreign tax paid can be credited. And for a "pure holding" company that only holds shares, the substance requirements are notably lighter.
✉️ We'll plan your Hong Kong holding so FSIE works in your favour. @PfserBot
