Hk China Double Tax Agreement

Prior to the December 2003 agreement, royalties granted by a Hong Kong resident from a Belgian source that was not attributable to any stable establishment in Belgium were subject to a Belgian withholding tax of 15% on the gross amount of royalties, net of a fixed deduction of 15%. Under the agreement, the Belgian withholding tax was set at 5% of the gross amount of royalties (excluding the 15% vat deduction). Drop. With regard to interest received by a Hong Kong resident residing in Belgium, which is not attributable to a stable establishment in Belgium, the Belgian withholding tax has been reduced from 15% of the gross rate to 10% under the agreement. In September 2012, the Commissioner for Finance stated that Hong Kong had made “remarkable progress” in establishing its international network of tax treaties since the change in the internal income system in March 2010, and that since then the network of tax treaties in Hong Kong has rapidly expanded. As of March 2018, 37 global double taxation agreements were in force in Hong Kong. In June 2001, Hong Kong concluded a limited maritime traffic agreement with the United Kingdom. The agreement is limited to revenues from international maritime traffic and provides that profits made by a UK company or SAR as a result of such transactions are exempt from the territory of the other party. The provisions of the agreement, which come into force on 3 May 2001, apply to corporation tax in the United Kingdom from 1 April 2002 and from 6 April 2002, apply to income and capital gains tax.

It applied to the RAD as of April 1, 2002. Under the agreement, Hong Kong residents who receive dividends from New Zealand that are not attributable to an institution in New Zealand are subject to a reduced withholding rate of 15%. The withholding rate is further lowered to 5% or 0% for eligible beneficiaries. Hong Kongers who receive royalties from New Zealand pay a withholding tax capped at 5%. The agreement was also the first Hong Kong DBA to be signed using the Organisation for Economic Co-operation and Development standard for the exchange of tax information. China The fifth protocol replaced the above-mentioned tie-break rule with an approach to mutual agreement. When a person other than a person is established on both sides, the competent authorities of China and Hong Kong endeavour, within the meaning of the DBA, to reach an agreement on the place of residence of which that person is considered resident. On 11 February 1998, Hong Kong and China signed the “Memorandum of Understanding between Mainland China and the Hong Kong Special Administrative Region to avoid double taxation of income” (limited agreement) in order to allocate the right to taxation between the two jurisdictions on an appropriate basis in order to avoid double taxation.

With regard to the new agreement, Donald Tsang announced that the agency is not entitled to tax relief or tax exemptions under the DBA without the mutual agreement of the competent authorities, except for the degree and nature of tax reliefs and exemptions agreed by other means by the competent authorities.