Comprehensive Double Taxation Agreements (CDTA)

List of Comprehensive Double Taxation Agreements (CDTA) signed between Hong Kong and other countries.

Comprehensive Double Taxation Agreements in Force

As of 27 February 2014, out of the 29 CDTAs, 28 of them are now in force:

Jurisdiction

Effective from

(Year of assessment)

Withholding tax rate under CDTAs

(Subject to certain conditions)

Dividends

Interests

Royalties

Austria

2012/2013

0% / 10%

0%

3%

Belgium

2004/2005

0% / 5% / 15%

0% / 10%

5%

Brunei*

2011/2012

0%

0% / 5% / 10%

5%

Canada

2014/2015

5% / 15%

10%

10%

China

2007/2008

5% / 10%

0% / 7%

7%

Czech Republic

2013/2014

5%

0%

10%

France

2012/2013

10%

0% / 10%

10%

Guernsey

2014/2015

0%

0%

4%

Hungary

2012/2013

5% / 10%

0% / 5%

5%

Indonesia

2013/2014

5% / 10%

0% / 10%

5%

Ireland

2012/2013

0%

0% / 10%

3%

Japan

2012/2013

5% / 10%

0% / 10%

5%

Jersey

2014/2015

0%

0%

4%

Kuwait

2014/2015

0% / 5% / 5%

5%

5%

Liechtenstein

2012/2013

0%

0%

3%

Luxembourg

2008/2009

0% / 10%

0%

3%

Malaysia*

2013/2014

5% / 10%

10%

8%

Malta

2013/2014

0%

0%

3%

Mexico

2014/2015

0%

4.9% / 10%

10%

Netherlands

2012/2013

0% / 10%

0%

3%

New Zealand

2012/2013

0% / 5% / 15%

0% / 10%

5%

Portugal

2013/2014

5% / 10%

0% / 10%

5%

Qatar

2014/2015

0%

0%

5%

Spain

2013/2014

0% / 10%

0% / 5%

5%

Switzerland

2013/2014

0% / 10%

0%

3%

Thailand

2006/2007

10%

0% / 10% / 15%

5% / 10% / 15%

UK

2011/2012

0% / 15%

0%

3%

Vietnam

2010/2011

10%

0% / 10%

7% / 10%

 * Technical fees of 15% applies in Brunei and 5% in Malaysia

Comprehensive Double Taxation Agreements Pending Ratification Procedures

There is one CDTA subject to ratification procedures of Hong Kong and the treaty country:

Jurisdiction

Withholding tax rate under CDTAs

(Subject to certain conditions)

Dividends

Interests

Royalties

Italy

10%

12.5%

15%

Document

Mazars - Hong Kong Tax treaties

Apr.2012 - Update on the Status of Hong Kong Tax Treaties

Since our last Hong Kong tax news on the above subject, there are further development on the Hong Kong tax treaty network.

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May 2010 - CTAs with Hungary Kuwait

Please find enclosed the latest edition of our Tax newsletter dealing with the two new Comprehensive Taxation Agreements recently signed by Hong Kong with Hungary and Kuwait.

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May 2010 - CDTA with Austria

Hong Kong signed a comprehensive double taxation agreement (“CDTA”) with Austria which has incorporated the latest OECD standard on exchange of information on 25 May 2010

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May 2010 - CDTA with Mainland China

Hong Kong signed the 3rd Protocol to the Comprehensive Double Taxation Arrangement with the Mainland China

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Sept. 2011 - Update on the Status of Hong Kong Tax Treaties

Since the commencement of the Inland Revenue (Amendment) Ordinance 2010 which enables Hong Kong to adopt The Organisation for Economic Co-operation and Development (“OECD”) 2004 version of Exchange of Information (EoI) Article, Hong Kong has been working very hard to expand its treaty network

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