On 22 May 2023, the Hong Kong Inland Revenue Department published two advance rulings dated 1 March 2023 in regard to the economic substance requirement under the new Foreign-Sourced Income Exemption (FSIE) regime introduced by the Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Ordinance 2022. As previously reported, the new FSIE regime essentially provides that offsh…