Explanatory notes

Note (1)

0% if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends. In all other cases, 10%.

Note (2)

5% if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends. In all other cases, 15%.

Note (3)

5% if the recipient is a bank or financial institution. In all other cases, 10%.

Note (4)

5% if the beneficial owner is a company directly owning at least 10% of the capital of the company paying the dividends. In all other cases, 10%.

Note (5)

5% if the beneficial owner is a company that directly owns at least 25% of the capital. In all other cases 10%.

Note (6)

10% unless paid to HKMA, a body owned or funded by the Government of the HKSAR, a bank or financial institution, paid by a bank or a financial institution, paid in respect of a sale on credit or to a person providing pension benefits.

Note (7)

The withholding tax is capped at 5% for a company holding (directly or indirectly) for a period of six months at least 10% of the voting shares of the company paying the dividends, and 10% for other cases.

Note (8)

0% if the beneficial owner is the government. In all other cases, 5%.

Note (9)

0% if the beneficial owner is a company that directly owns at least 10% of the capital of the company paying the dividends or a participation with an acquisition cost of at least EUR1.2 million in the company paying the dividends. In all other cases, 10%.

Note (10)

5% if the beneficial owner is a company that directly holds at least 25% of the capital of the company paying the dividends. In all other cases, 10%.

Note (11)

0% if the beneficial owner is a company directly owning at least 10% of the capital of the company paying the dividends, provided that:

• the shares are traded on a recognised stock exchange, or
• at least 50% of the shares in the qualifying recipient company are regularly traded on a recognised stock exchange.

In all other cases, 10%.

Note (12)

5% if for the use of, or for the right to use, any copyright of literary, artistic or scientific work. 10% if for the use of, or for the right to use, any patent, trademark, design or model, plan, secret formula or process. In all other cases, 15%.

Note (13)

10% if the recipient is a financial institution or insurance company, or in respect of arm’s-length transactions concerning the sale of equipment, merchandise or services. In all other cases, 15%.

Note (14)

Except where the beneficial owner is a pension scheme dividends paid by property investment vehicles such as REITs will be subject to a withholding tax of 15%.

Note (15)

7% if for the use of, or for the right to use, any patent, design or model, plan, secret formula or process. In all other cases, 10%.