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Since the enactment of the Inland Revenue (Amendment) Ordinance 2010, Hong Kong has concluded several Comprehensive Double Taxation Agreements (“CDTAs”) that have adopted the latest Organization for Economic Co-operation and Development standard on the Exchange of Information:
Withholding Tax Rates Under Hong Kong Treaties
Country |
Dividends |
Royalties |
Interest |
| Austria |
Nil-10%(1) |
3% |
Nil |
| Belgium |
5-15%(2) |
5% |
10% |
| Brunei Darussalam |
Nil |
5% |
5-10%(3) |
| France |
10% |
10% |
10% |
| Hungary |
5 – 10%(4) |
5% |
5% |
| Indonesia |
5-10%(5) |
5% |
10% |
| Ireland |
0 |
3% |
10-15%(6) |
| Japan |
5 % (7) |
5% |
10% |
| Kuwait |
0-5%(8) |
5% |
5% |
| Liechtenstein |
0 |
0% |
0% |
| Luxembourg |
0-10%(9) |
3% |
Nil |
| Mainland China |
5-10%(10) |
7% |
7% |
| The Netherlands |
0-10%(11) |
3% |
Nil |
| Thailand |
10% |
5-10%(12) |
10-15%(13) |
| United Kingdom |
0-10%(14) |
3% |
Nil |
| Vietnam |
10% |
7-10%(15) |
10% |
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| 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%. |
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