Key takeaways
Host: Vivien Wang, partner, Deloitte US
Presenters: Jonathan Culver, partner, Deloitte China
Anthony Lau, partner, Deloitte China
Kwan Yu, partner, Deloitte China
In response to the EU placing Hong Kong on the “grey list” for tax cooperation, the Hong Kong Special Administrative Region (HKSAR) government has recently issued a consultation on proposed refinements to its FSIE regime to be effective on January 1, 2023. The refined FSIE regime strives to tackle double non-taxation on offshore passive income while upholding an attractive tax regime in Hong Kong. We’ll discuss:
- Type of “in-scope passive income” subject to the refined FSIE regime
- Exemption conditions and relief under the refined FSIE regime
- Additional tax compliance requirements under the refined FSIE regime
Meet the host

Vivien Wang
Vivien has more than 18 years of public accounting and international tax experiences, providing tax consulting, compliance, and tax accounting assurance services to various high-tech and venture capital clients. Her experience includes structuring and globally managing both US inbound and outbound investments. Vivien assisted in the planning and implementation of the worldwide restructurings, mergers, acquisitions, and IP migrations for multinational clients. Vivien is also the National Tax leader of Deloitte’s US Chinese Services Group, specializing in China strategy planning for US companies and investment funds and US inbound investment issues for China based investors. Vivien is our US Inbound Practice leader for the West Region, focusing on serving foreign company’s investments in the US through both M&A and greenfield investment.
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