Hong Kong companies are not taxed on their worldwide income. Foreign-sourced income is generally not taxed. However, under the refined FSIE regime, effective from 1 January 2023, four types of offshore income, namely (i) interest, (ii) dividends, (iii) equity interest disposal gains, and (iv) IP income, are deemed to be sourced from Hong Kong SAR and chargeable to profits tax if the income is received in Hong Kong by an MNE (multinational enterprise) entity carrying on a trade, profession, or business in Hong Kong and the recipient entity fails to meet a relevant exception from the deeming provision. With effect from 1 January 2024, the scope of ‘specified foreign-sourced income’ is expanded to include disposal gains on other types of assets (in addition to equity interests).