On 5 July 2024, the Inland Revenue Department (IRD) released further guidance on the foreign-sourced income exemption (FSIE) regime by expanding the list of related Frequently Asked Questions (FAQs) and illustrative examples on its website. The IRD also uploaded an FAQ to clarify the tax treatment of interest income derived by a fund, a family-owned investment holding vehicle (FIHV) or its special purpose entity (SPE) from foreign debt instruments, including the relevant tax implications under the FSIE regime.
This news flash summarises the above new guidance and our observations thereon.