BDO hybrid event: Foreign-sourced income exemption

Date: 16 December 2022
Time: 15:00 - 16:30
25th Floor, Wing On Centre
111 Connaught Road Central
Hong Kong  
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  • Summary

The Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Bill 2022 (Bill) gazetted on 28 October 2022 introduces very significant changes to Hong Kong’s offshore tax exemption on passive income. It is expected that the Bill will be passed by the end of this year, and the refined regime will become effective from 1 January 2023. 

Corporate groups having companies in more than one jurisdiction will fall into scope for the new regime. SMEs and local groups will be caught as well unless their groups comprise only domestic Hong Kong companies.

Once in scope, exemption from Hong Kong profits tax in respect of foreign-sourced dividends, interest, intellectual property income and disposal gains is available only if the relevant conditions are met. Offshore claims on such passive income are no longer straightforward in Hong Kong from next year; there are hurdles to be overcome.

In this event, we will share with you the following:

  • An overview of the Bill
  • The administrative guidance provided by the Inland Revenue Department
  • Practical considerations in complying with the new requirements, and
  • How BDO can help

This is a hybrid event. Seats are limited and available on a first-come-first-served basis. There will be case studies and interactive Q&A session to address any questions you may have. Hence, please come to our physical event and meet up with our speakers in person to discuss this important change to the Hong Kong tax legislation. 



AGNES CHEUNG, Director and Head of Tax, BDO

Agnes has extensive experiences in providing Hong Kong and international tax compliance and advisory services to multinational companies as well as Chinese state-owned enterprises across different industries. In particular, Agnes is experienced in advising group restructuring, merger and acquisition and cross border transactions.

Agnes also specialises in the asset and wealth management industry. She has advised numerous private equity, venture capital and hedge funds, as well as family offices on their tax issues including top side and downstream structuring, eligibility for preferential tax treatments, field audit and tax investigation by the IRD. She is specialised in the Hong Kong offshore fund law, offshore fund law for private equity funds and the newly enacted unified fund exemption and carried interest exemption regimes.

Agnes has acted as a technical reviewer in assisting Wolters Kluwer to review the Hong Kong Master Tax Guide for almost 10 years. She is a frequent speaker and contributor of articles on international tax journals, local magazines and newspapers.

Agnes is a Hong Kong Certified Public Accountant, Fellow member of the Taxation Institute of Hong Kong and Fellow member of the Association of Chartered Certified Accountants. 


ABIGAIL LI, Director of Tax, BDO

Abigail has extensive experience in Hong Kong and international tax and in a wide range of industries including asset management and financial services, corporate treasury, commodities, shipping, industrial and consumer products. Her clients have ranged from well-established large multinational companies (MNCs) to start-ups or new economy companies.

Abigail is experienced in advising on sophisticated technical tax issues in Hong Kong, and also in respect of cross border transactions involving Hong Kong including tax planning, group structuring, M&A and cross border financial products or transactions.

Abigail is also experienced in assisting clients in various applications with the Hong Kong Inland Revenue Department and Stamp Office including application for advance ruling, certificate of tax residency and stamp duty relief.

Abigail has in-house experience as an Asia Pacific tax manager in a US listed Fortune 500 MNC, resolving local and regional tax issues from operations, treasury, etc.

Abigail's recent projects include structuring tax advice in respect of fund formation and asset management group, tax due diligence for M&A, legal entity rationalisation, financial assets sale and purchase, securitisation, aircraft and ship leasing, etc. She is also a contributor of tax articles for tax journals and publications.

Abigail is a Fellow of the Association of Chartered Certified Accountants (ACCA) and Member of ACCA Tax Subcommittee. 

CAROL LAM, Director of Tax, BDO

Carol has extensive experience in providing Hong Kong and international tax consulting and compliance services to multinational corporations, listed groups as well as private companies from a wide range of industries, including manufacturing, trading, retail, real estate, financial services, transportation, aircraft and logistics and professional firms.

Carol is experienced in advising on tax-efficient operation, holding and financing structure, corporate restructuring, pre-listing tax planning, cross border transactions, due diligence and mergers & acquisition deals. She also has extensive experience in advising international assignees in structuring tax-efficient remuneration packages, and in representing clients in tax investigation and field audit cases and handling tax dispute settlement. 

Carol is a Hong Kong Certified Public Accountant, Fellow of the Association of Chartered Certified Accountants and Council Member of The Taxation Institute of Hong Kong. 

Further information
(For online event) This event will incorporate slides which you can view on a PC and audio broadcast technology which requires only the speakers in your device. Therefore, on the day, please ensure the audio volume of your device is turned up. You are recommended to log in the webinar (which will be provided by email after your successful registration) a few minutes before the webinar starts to make sure you have no problem with the connection. 


Details are as follows:

Date : Friday, 16 December 2022
Time : 15:00 – 16:30
Venue : Hybrid (Online via Zoom /In-person at BDO office)
    25th Floor, Wing On Centre
    111 Connaught Road Central, Hong Kong
    (Sheung Wan Wing On Department Store’s building)
Language : Cantonese
Fee : Free of charge
CPD Units* : 1.5 hours (*The recognition of CPD hours by your professional organisations is subject to their CPD policies.)
Remarks : 1. For any enquiries, please contact contact Ida Cheung at +852 2218 3714 or [email protected] 
    2. Login information will be sent to you by email after successful registration.
    3. Seats are limited and available on a first-come, first-served basis.
    4. BDO reserves the final right of acceptance of registration.