Canadian Prime Minister Justin Trudeau attended the ASEAN Summit in Phnom Penh, Cambodia last week where he announced the funding support.
Myanmar Junta Risks Total Ban at ASEAN Meetings
Leaders of ASEAN countries have warned Myanmar that it needs to proceed with an actionable peace plan or risk removal from the bloc’s meetings as an aftermath of the social and political chaos engulfing the nation.
Public Relations Practitioners Affirm the Future of PR at Inaugural IPRS PRISM Summit 2022
With the effects of the COVID-19 pandemic and the recent global, political, and economic turmoil, PR practitioners are re-evaluating their roles and the need to evolve to remain relevant in meeting new challenges. In addition, the demand to adapt to emerging technologies and ESG (environmental, social, and governance) in forming business strategies also adds new dimensions to the PR practice.
The IPRS organised the summit to bring the PR community together and to exchange in-depth knowledge across key areas such as sustainability and technology. Through these discussions, the delegates also had the opportunity to contribute actionable insights and tips in navigating the volatile business and social environments and the evolving communications industry.
The summit featured 32 speakers. In addition to Professor Tommy Koh, other speakers included Ms. Su-Yen Wong, Chairperson at the Singapore Institute of Directors, and Mr. Jacob Puthenparambil, Founder and CEO of Redhill, with topics addressing leadership, ESG, technology, and future readiness. Other domain experts also shared insights on the opportunities and challenges of the current outlook and how PR is essential for organisations in their growth and long-term viability.
In the keynote panel, Mr. Jacob Puthenparambil, Founder and CEO of Redhill, said that the most significant change isn’t technology but economics and that the media model is changing. He also described the role of the PR practitioner as multi-prong — like an accountant who understands the economics of the business, a lawyer who constructs sound arguments, and a service personnel who is often the ‘face’ of the organisation, calm and graceful even in challenging situations.
Ms. Wong Su Yen, Chairperson at the Singapore Institute of Directors, offered three Cs on how PR practitioners bring value to senior leaders and their Boards – helping the Board curate the narrative, control the crisis, and coach the team. For those who aspire to roles on Boards, she shared that they should view directorships just like any profession and build up skills and experience in areas such as business strategy, finance, and accounting, as well as have a good understanding of regulations.
Mr. Tham Kok Wing, Director at Robertsbridge Stonehaven Singapore, also spoke in a panel on “Shaping Your Sustainability Story.” He urged everyone to take the opportunity to embrace ESG and bring about change in their respective organisations. To do this, he said that “Design Thinking, Systems Thinking, and Futures Thinking” was needed.
IPRS was formed in 1970, and the institute continues to grow Singapore’s PR industry through knowledge acquisitions, networking, and exchanging of new ideas. Through this, it aims to be the leading regional PR organisation that elevates the profession, sets industry standards, and increases public recognition.
“The IPRS was established in the earliest days of Singapore’s PR practice. Today, it continues to uphold the profession’s value to people and organisations. Through this Inaugural IPRS PRISM Summit 2022, we challenged our industry to refresh the purpose of communications and make a difference now and in the future. We were thrilled to have had the honour of welcoming and hosting our distinguished speakers, IPRS members, practitioners, and friends of our PR community,” says Koh Juat Muay, President of IPRS.
“It is exciting times for public relations professionals. However, the PR profession must evolve to ensure that we remain relevant. PR is no longer only about working with the media. Today, we are ESG leaders, brand ambassadors, social media experts, marketers, risk managers, and more. The strong support we have received from organising a summit like this is proof that the industry is indeed shifting and that change is becoming increasingly necessary.” says Vanessa Wan, Chairperson of the IPRS PRISM Summit and IPRS Council Member.
The PRISM summit was supported and made possible by Platinum Sponsor Redhill and Gold Sponsors IN.FOM, Truescope, and Dataxet.
For more information on the IPRS and the IPRS PRISM Summit 2022, please visit www.iprs.org.sg
Hashtag: #IPRS
The issuer is solely responsible for the content of this announcement.
About IPRS PRISM
The IPRS introduced PRISM in our industry awards in 1987 to recognise and reward excellence in PR and Communications in Singapore and the region. PRISM which stands for Public Relations in Service of Mankind is today our signature and ethos. The IPRS PRISM Summit will be held biennially, alternating with the IPRS PRISM Awards. Together they present a community platform to lead and showcase the PR industry’s best in Singapore and the region.
About IPRS
IPRS, established in 1970 as a non-profit organisation, is the only accrediting body for Public Relations (PR) practitioners in Singapore. The Institute promotes excellence in the industry through knowledge exchange platforms and training programmes that are aligned with the many changes and developments in the practice of PR and Communications today.
IPRS has a growing membership consisting of professionals from diverse backgrounds in public relations, journalism, advertising, marketing, education, and management – a factor that has contributed to the Institute’s strength and dynamism.
There are 10 Student Chapters with various tertiary institutions to create opportunities for communications students and IPRS members to share expertise and experiences. The IPRS introduced the Biennial PRISM Awards (Public Relations In the Service of Mankind) in 1987 to recognise and reward excellence in PR and Communications in Singapore and the region.
Olymp Trade launch the 8th anniversary event
The birthday events lasted for a week, from October 24 to 30, including both platform activities for traders and games on social media for the brand’s followers. A large-scale birthday quest took place on Facebook, where all participants were given bonuses from the platform, while winners were awarded branded merchandise and smartphones. Olymp Trade was not just celebrated by its community on its birthday, but also by football player Ronaldinho Gaúcho, Indian cricketer Shikhar Dhawan and YouTuber Elvish Yadav.
Olymp Trade held its eighth anniversary under the slogan “Discover your freedom.” For its users, freedom is not an abstract notion but an opportunity the platform gives. With almost 200 assets, three trading modes and up-to-date training materials, Olymp Trade provides a space that allows traders to unleash their potential while exploring and advancing their trading.
During the celebration, the trading community also gave positive feedback to the platform.
Sumit KaDyan from India said: “I had many bad experiences on other platforms offering a similar kind of service, but here on Olymp Trade, I never had such issues, which gave me confidence and built my trust on this platform.”
Ismael Jako from Egypt agreed: “I joined the world of traders, and I have already made friends. We trade with each other. I share my stories with other Olymp Trade users. I hope it will continue to be so.”
Today, the online platform has about 88 million users, with more than 1 million trades executed daily. Olymp Trade is available worldwide in 14 languages. More than 2 million followers subscribe to the broker’s news and updates on social networks, forming a community of people united by the philosophy of free trading.
Trading always carries a risk of loss. All trades and investment decisions are made by readers at their own risk and through their own judgment.
Hashtag: #OlympTrade
The issuer is solely responsible for the content of this announcement.
Hong Kong Baptist University Global University Film Awards 2022 presents Gold Award to France’s Le Fresnoy

This year’s award presentation ceremony was broadcast live in online format in a wonderfully designed cinematic setting, using virtual sets and advanced technology to recreate classic scenes in blockbusters such as The Matrix, the Harry Potter film series and In the Mood for Love.
In his opening remarks at the ceremony, Dr Clement Chen, Chairman of the Council and the Court of HKBU, shared the delights of seeing GUFA held for the third time. “We hope to stand as a beacon of encouragement to emerging filmmakers, allowing them to create their art without commercial considerations and industry pressures. At university, they are free to let their imagination fly, share their concerns and explore creative ideas. We at HKBU embrace these ideals and, for over four decades, have been offering the finest teaching and training in the cinematic arts. We continue to celebrate this legacy today as we nurture tomorrow’s filmmakers.”
In his speech, Professor Alexander Wai, President and Vice-Chancellor of HKBU, said: “HKBU is the first institution in Hong Kong to offer film and video production programmes and we always have our eyes on the future. Filmmaking is a global community, and GUFA is a way for all of us to celebrate new young talents from all over the world. It gives me great delight to have a sneak peek at the future voices of filmmaking and to celebrate their progress.”
Widely known as the “University Oscars”, this year GUFA received more than 2,300 submissions from about 100 countries and regions. Celebrated professionals in the film industry, including directors Ms Mabel Cheung, Mr Derek Tsang, Ms Jessey Tsang, Mr Ray Yeung, and actress/producer Ms Josie Ho presented 15 awards to the young film talents from all over the world, letting them shine on a glamorous virtual stage.
To further showcase the exemplary works at GUFA 2022, a public screening of the winners will be held on 15 November at HKBU. Members of the public are welcome to attend. For more information, please refer to the GUFA website, GUFA Facebook page and GUFA YouTube channel.
GUFA recognises the excellence of film productions by university students from across the world by connecting the global film community and its audiences with the outstanding works and groundbreaking ideas presented by the participants. The event not only showcases the students’ talents but also fosters the exchange of ideas and enhances professional networks, building synergy between young regional talents and the international creative industry.
Appendix: Award winners
Award | Winning film | University |
Best Narrative | Good German Work | Konrad Wolf Film University of Babelsberg, Germany |
Special Mention of Narrative | When Summer Ends | Hong Kong Baptist University, Hong Kong |
Best Cine-VFX | Little Gestures | Pearson College London, United Kingdom |
Special Mention of Cine-VFX | 17 Souls | University of Television and Film Munich (HFF München), Germany |
Best Documentary | Pupus | Centro Sperimentale di Cinematografia- Sede Sicilia, Italy |
Special Mention of Documentary | Broken | Yangon Film School, Myanmar |
Best Experimental Film | $75 000 | Le Fresnoy, France |
Special Mention of Experimental Film | In Plain Sight | Chulalongkorn University, Thailand |
Best Animation | Graziano and the Giraffe | Centro Sperimentale di Cinematografia, Italy |
Special Mention of Animation | A Dog under Bridge | China Academy of Art, Mainland China |
Best Director | To Each Your Sarah | Korea National University of Arts, South Korea |
Best Script | Russian Vodka | University of Applied Science and Technology, Iran |
Gold Award | $75 000 | Le Fresnoy, France |
HKBU Academy of Film’s Choice | Intimate Distance | Hong Kong Baptist University, Hong Kong |
HKBU Academy of Film’s Choice Special Mention | Love Delivery | Hong Kong Metropolitan University, Hong Kong |
Hashtag: #HongKongBaptistUniversity #HKBU
Gunung Raja Paksi bolsters commitment to the production of sustainable steel in Southeast Asia via two MoU signings with Fortescue Future Industries and KADIN
The recent new MoU signings are in line with GRP’s mission to decarbonise the regional steel industry as outlined in its most recently launched ESG Strategy Handbook
JAKARTA, INDONESIA – Media OutReach – 14 November 2022 – PT Gunung Raja Paksi Tbk (GRP), a member of Gunung Steel Group and one of the largest private steelmakers in Indonesia today, reaffirmed their commitment towards sustainable steel manufacturing for the Southeast Asia region by signing two new Memorandum of Understandings (MoUs), one with Fortescue Future Industries (FFI), a global green energy company and the other with Indonesian Chamber of Commerce and Industry (KADIN), the government agency driving business and economic development in Indonesia.

The MoU with FFI explores collaboration on green hydrogen and green ammonia use cases, whereas the agreement with KADIN pledges GRP’s commitments towards net zero, which are key focus areas following the release of their recent Environmental, Social and Governance (ESG) Strategy Handbook. These will propel the company forward in its agenda of decarbonising the region’s steel industry through accelerating net zero emissions and promoting the use of green energy, which are key focus areas in its ESG strategy.
Steel production is one of the world’s most polluting and energy consuming activities making it a major contributor to global emissions. According to the World Economic Forum, Asia’s steel industry alone accounts for more than 70% of the carbon emissions in global steel production to date. As the largest steelmaker in Indonesia, GRP is leading the charge as exemplified by these MoUs, which lay the foundation for further environmental initiatives in the coming future.
“Given the devastating impact of climate change, it has become a business imperative for leaders to act towards ensuring a sustainable supply chain in their growth journey. The steps we take today will build the future for tomorrow, therefore we are working with these partners who have the expertise to drive our business and the steel industry to a prosperous and more environmentally friendly future,” said Tony Taniwan, Executive Committee at GRP.
Under this MoU, GRP will be collaborating with FFI to explore technical and commercial use cases for green hydrogen and green ammonia as well as the implementation of technologies aid in the utilisation of green energy in the supply chain and potential offtake collaboration. The use of green hydrogen could allow GRP to produce low-emission steel in what is a particularly hard-to-abate sector. This is one of key action items in transforming the steelmaking operations in particular to the environmental impact of the business.
“We are leveraging the right knowledge and expertise to incorporate sustainability initiatives alongside business processes in helping to make our sustainability strategy more viable in the long term. We also wanted to ensure the positive impact of economic growth is not achieved with the expense of our people and environment,” said Kimin Tanoto, Executive Committee at GRP.
“Working with FFI and KADIN, both who are knowledgeable and experienced within their own fields, will help us discover and embrace the right technologies and methods of harnessing these cleaner solutions while paving the way forward towards net zero in the region,” said Kelvin Fu, Advisor at GRP.
“Fortescue is the only major heavy industry company in the world with a real construction plan to get to real zero and we are already rapidly beginning to acquire and implement the technology required to deliver on our 2030 decarbonisation target. If we are to have the impact needed to reduce carbon emissions, we cannot do this alone. We need other emitters – companies like GRP – to follow our lead and we are determined to do everything in our power to help them on their own path to decarbonisation,” says Dr Andrew Forrest AO, Chairman and Founder of Fortescue.
To propel Indonesia forward towards its goal of reaching net zero in 2060, GRP has partnered with KADIN under its Net Zero Hub initiative which is designed specifically to support Indonesia’s private sector in their journey in achieving net zero emissions. Under this partnership, GRP reaffirms their pledge to net zero and will work closely with KADIN to identify clear benchmarks and priorities for decarbonisation to help the company reach its net zero target.
“With our recent initiatives such as the ESG Strategy Handbook and the recent MoU signings which study the use of next generation technology and pledge towards net zero, we are well positioned to further our way towards more sustainable production of steel,” said Sheren Omega, Head of Sustainability of GRP
“Currently, we are witnessing Indonesia being on track towards achieving net zero in 2060, with policy developments in the making such as the formulation of a carbon tax to be imposed on fired power plants and investments into solar panels and electric vehicles. This can only be achieved with collaboration with private sector partners such as GRP. We hope that this MoU will pave the way for future partnerships with more industry players to build a low carbon industry ecosystem for the future generations of Indonesia,” said Muhammad Yusrizki, Chairman of Renewable Energy Committee at KADIN.
GRP is dedicated towards the sustainable production of steel in the region and seeks to work closely with stakeholders from the government and private sector as part of its mission. To foster collaborations and alignments in building a sustainable future, GRP participated in the panel discussion on 11th November at the Indonesia Net Zero Summit, discussing the importance of decarbonising the industry’s supply chain.
Hashtag: #GunungRajaPaksi
About GRP
PT Gunung Raja Paksi Tbk (GRP) is part of the Gunung Steel Group, which is one of Indonesia’s major private steel businesses. Our company began its operations in 1970 in Medan, North Sumatra, by producing hot steel, then progressed to manufacture steel beams and sheets.
With over 50 years of steel industry experience, GRP has a production capacity of 2,200,000 tons of high-quality steel annually approved by local and international certifying company.
Today, our company has become one of the largest private steel companies in Indonesia. Gunung Raja Paksi, “Shaping Tomorrow”. Together we develop a better future.
About Fortescue Future Industries (FFI)
Fortescue Future Industries (FFI) is a global green energy company committed to producing green hydrogen, containing zero carbon, from 100 per cent renewable sources.
Green hydrogen is a zero-carbon fuel that when used produces primarily water. It is a practical and implementable solution that can help revolutionise the way we power our planet: helping to decarbonise heavy industry and create jobs globally.
FFI is leading the green industrial revolution, developing technology solutions for hard-to-decarbonise industries, while building a global portfolio of renewable green hydrogen and green ammonia projects.
FFI is also leading the global effort to help decarbonise hard-to-abate sectors and is developing and acquiring the technology and energy supply to help decarbonise the iron operations of one of the world’s largest producers of iron ore by 2030 (Scope 1 and 2) – our parent company Fortescue Metals Group (ASX FMG).
About KADIN
Kadin or Chamber of Commerce and Industry is the umbrella organisation of the Indonesian business chambers and associations. It is focused on all matters relating to trade, industry, and services, and is highly committed to tapping potentials and synergies of the national economy, offering a strategic forum for Indonesian entrepreneurs.
For more information, please visit: www.gunungrajapaksi.com
Cheng & Cheng Taxation Reveals How the Foreign-Sourced Income Exemption Regime Is a Radical Change to the Source Concept of Hong Kong’s Taxation System
The HKSAR Government will be introducing a Foreign-Sourced Income Exemption (FSIE) regime, with a target enforcement date of 1 January 2023. The new FSIE regime will have a significant impact on the source concept of Hong Kong’s taxation system. Hong Kong has long been famous for its territorial-based principle of taxation, in which non–Hong Kong sourced income is not subject to Hong Kong Profits Tax. However, as this could give rise to double non-taxation on a project, such a tax treatment principle is deemed to be harmful to international tax standards and has recently aroused great concern from the European Union (EU).
To address the EU concerns, the HKSAR Government has issued a consultation paper to introduce the FSIE regime, which imposes additional rules on the offshore claims of the following four types of income:
- Interest income
- Dividend income
- Disposal gains (equity interest)
- Intellectual property (IP) income
Active income, such as trading profits and service income, are not covered under the FSIE regime.
Base rules under the proposed FSIE regime
The refined FSIE regime only targets the Hong Kong constituent entities of multinational enterprise (MNE) groups. It also specifically targets passive income that is received in Hong Kong.
By following the approach adopted in Singapore, an income is regarded as received in Hong Kong if:
- It is remitted to Hong Kong (e.g., remitted to a Hong Kong bank account);
- It is used to settle debt incurred in respect of a business carried on in Hong Kong; or
- It is used to buy movable property, which is subsequently brought into Hong Kong.
Protection from double-taxation under the FSIE regime
Under normal circumstances, a tax credit is generally available in Hong Kong in the case of double-taxation issues for Hong Kong’s Comprehensive Double Taxation Agreement (DTA) partners. In other words, no tax credit is available to non-DTA partners.
However, if a non–Hong Kong sourced passive income becomes subject to Hong Kong Profits Tax under the FSIE regime, a tax credit will be available in Hong Kong if the concerned income is also subject to tax of a similar nature in other tax jurisdictions, no matter whether the counterparty is a DTA partner or not. The rationale is that the FSIE regime is being enacted solely in response to pressures from the EU, rather than to raise tax revenues in Hong Kong.
As a result, taxpayers who have already paid foreign tax on their passive income should be more relaxed under the proposed FSIE regime.
Recap of Hong Kong’s source rule on passive income
The basic principle of determining the source of the four types of concerned passive income under Hong Kong Profits Tax is shown below.
Affected income | Source rule |
Interest income | Provision of credit test/operation test |
Dividend income | Tax residency of the investment (100% non-taxable under all scenarios) |
Disposal gains (equity interest) | Listed shares: location of stock exchange Unlisted shares: place where the sales contracts are effected |
IP royalty income | Contract effected test Intellectual property DEMPE functions location |
Interest income: For simple loan arrangements, provision of the credit test applies where the source depends on the location in which the loan funds were first made available to the borrower. For moneylenders, corporate treasury centres and more complicated situations, the operation test applies. It is worthwhile noting that the Hong Kong Inland Revenue Department increasingly uses the operation test to determine the source of interest income.
Dividend income: As Hong Kong–sourced income is also exempt from Hong Kong Profits Tax, dividend income was 100% non-taxable in Hong Kong before the introduction of the FSIE regime.
Disposal gains: Long-term investment capital gains are non-taxable in Hong Kong, which is the cornerstone of Hong Kong’s taxation system. What is uncertain at the moment is whether the FSIE regime will override the capital gains claim benefits of the Hong Kong tax system.
IP income: The contract effected test and the place of usage of the IP are the two traditional criteria for determining the source of royalty fees. Following international practice, the location in which the DEMPE functions (development, enhancement, maintenance, protection and exploitation) of the IP is carried out is now also an important criteria.
Proposed FSIE regime on four specific covered income types
In addition to the above current source rule of Hong Kong, in order to pursue an offshore profits claim in Hong Kong, taxpayers also have to fulfil the following rules under the proposed FSIE regime:
Covered offshore income | Applicable rule |
Interest income | Economic substance rule |
Dividend income | Economic substance rule or participation exemption |
Disposal gains | Economic substance rule or participation exemption |
IP income | Nexus approach |
All covered passive income received by covered taxpayers not in-scope of the exemption rules are liable to profits tax in Hong Kong.
Economic substance rule (interest income, dividend income, disposal gains)
Pursuant to the economic substance rule, taxpayers have to build up economic substance in Hong Kong in order to successfully pursue an offshore claim in Hong Kong. The logic is that the taxpayers have to demonstrate that Hong Kong (rather than other tax jurisdictions) possesses the taxing rights under international standards because its economic substance is in Hong Kong. The taxpayers in the end do not have to pay tax due to the local legislation in Hong Kong. This is similar to the current economic substance law in offshore jurisdictions (such as the BVI and the Cayman Islands).
To fulfil the economic substance rule, covered taxpayers will need to meet the adequacy test, as follows:
- Employ an adequate number of qualified employees; and
- Incur an adequate amount of operating expenditure in Hong Kong in relation to the relevant activities.
Outsourcing of income-producing operations to another Hong Kong company is possible, provided that the taxpayers have control over the outsourced operations’ activities.
The proposal does not specify the exact number of employees or the amount of expenses required, but does note that, for a pure equity holding company which derives dividend income and equity interest disposal gains only, the requirements are more relaxed.
For interest income recipients, the taxpayers have to demonstrate that the relevant strategic decisions and the relevant loan financing arrangements are made in Hong Kong first, before the application of the interest income source rule (that is, the provision of the credit test or operation test).
Participation exemption (dividend income, disposal gains)
Even if the offshore dividend income or disposal gains do not fit the economic substance requirements, taxpayers are still eligible to pursue an offshore claim in Hong Kong when they meet the participation exemption requirements.
Under participation exemption, all of the following rules must be satisfied in order to pursue a non-taxable claim in Hong Kong:
- The income recipient (holding company) is a Hong Kong tax resident or a Hong Kong Permanent Establishment of a non-tax resident;
- The income recipient holds at least 5% of the shares or equity interest in the investee company;
- The income recipient has continuously held its shares or equity interest in the investee company for 12 months or longer before the income accrues to the income recipient;
- Switch-over rule: The corporate income tax rate of the investee company is at least 15%;
- Main purpose test (General Tax Anti-Avoidance Rule): If the Inland Revenue Department considers that the main purpose of the whole arrangement is for tax avoidance, participation exemption will not be fulfilled; and
- Anti-hybrid mismatch rule: The dividend payments of an investee company should not be tax-deductible.
MNE groups very often have complicated shareholding structures, in which the direct investee company of the Hong Kong holding company may not be the operating entity. In the case of dividend income, it is further explained in the tax bill that a “see-through” approach will be adopted, such that the underlying dividends and/or profits of up to five tiers of investee entities will be considered when assessing whether the switch-over rule (Point 4 above) is met. The tax bill does not mention whether the same approach shall apply in the case of disposal gains.
Nexus approach (IP income)
First of all, the exemption introduced in the proposed regime only covers income from patents and other IP income of a similar nature. Other intellectual property, such as trademarks or copyrights, is not applicable to any exemption and, therefore, all in-scope IP income generated from trademarks and copyrights would be deemed as taxable in Hong Kong. However, taxpayers are reminded to go through the base rules of the proposed regime to ascertain whether the IP income is in-scope or not (i.e., if the income recipient is part of an MNE group and the income is received in Hong Kong).
For income from patents, the nexus approach will be used to calculate the IP income qualifying for non-taxable claims under the FSIE regime (that is, in addition to the above source rule requirement). The calculation formula is as follows:
Qualifying expenditure incurred by the taxpayer to develop the IP assets | / | Overall expenditure incurred by the taxpayer to develop the IP assets | X |
IP income from the qualifying IP asset |
Based on the above formula, the next question would be the determination of “qualifying expenditure” (i.e., the numerator of the above formula).
In order to qualify as qualifying expenditure, the location requirement under different scenarios is as follows:
Persons responsible for the research & development (R&D) work | Location requirement |
Taxpayer itself | Hong Kong or overseas |
Outsourced to an unrelated party | Hong Kong or overseas |
Outsourced to a related party | Hong Kong |
Another thing to note is that qualifying expenditure does not include the acquisition costs of the IP asset. However, the amount of qualifying expenditure can be uplifted by 30% (subject to a cap equal to the overall operating expenses incurred by the Hong Kong taxpayer).
Based on the above formula, if the majority or all of the R&D work of the Hong Kong company is outsourced to an overseas related party, it is unlikely that the Hong Kong company can pursue an offshore claim on the IP income.
Another important note is that the R&D expenses paid by a Hong Kong taxpayer to overseas group companies are unlikely to be tax-deductible. If the corresponding IP income is not eligible for an offshore claim in Hong Kong, the Hong Kong company may end up having significant Hong Kong Profits Tax liabilities. For further details, please refer to:
https://henrykwongtax.com/article/cheng-cheng-taxation-reveals-how-super-tax-deduction-on-rd-activities-in-hong-kong/.
Significant impact on MNEs
Henry Kwong, Tax Partner of Cheng & Cheng Taxation Services Limited, explains: “Based on our experience, offshore claims in Hong Kong are a significant part of the tax planning of MNE groups, while it is common that these MNE groups may maintain limited or even no economic substance in Hong Kong. As such, we believe that the proposed FSIE regime is going to affect a significant number of MNE groups.”
The proposed FSIE regime will require these MNE groups to build up economic substance in order to enjoy preferential tax treatment in Hong Kong. While it may increase the financial burden on MNE groups, the proposed regime can potentially enhance the employment market in Hong Kong. MNE groups currently pursuing offshore claims in Hong Kong are advised to consult their tax advisors to perform a tax health check before the year 2023 and to make the necessary operational reforms.
Hashtag: #ChengChengTaxation
About Cheng & Cheng Taxation Services
Cheng & Cheng is one of the top 20 accounting firms in Hong Kong, with over 250 staff in Hong Kong and Mainland China. We are the principal auditor for around 20 listed corporations in Hong Kong and the tax advisor for over 80. We specialise in providing Hong Kong, Mainland China and international tax advisory services, as well as transfer pricing services to international clients. If you would like to know more about transfer pricing in Hong Kong, or seek tax advice from our tax experts, please do not hesitate to contact us by email ( henry.kwong@chengtax.com.hk) or phone (+852 3962 0114 / +852 5600 1980).
Thai Man Arrested at a Friendship Bridge for Carrying Illegal Items

Police arrested a Thai man at the first Laos-Thai Friendship Bridge in Vientiane after discovering various illegal items inside his car.