Global investors can often find themselves in the unfavorable position of having their income taxed twice — once by the country where the income originates, and again by their country of residence — unless a Double Taxation Agreement (DTA) is in place.
For example, a Hong Kong-resident company earning royalties, dividends, or interest income from a foreign jurisdiction could find that income subject to withholding taxes in that country on top of any liability at home. DTAs address this by clarifying which jurisdiction has taxing rights, reducing applicable withholding tax rates, and providing mechanisms to eliminate or offset the duplicated tax burden.
Hong Kong's treaty network entered 2026 with visible momentum. On January 30, 2026, the DTA with Türkiye entered into force, with application to Hong Kong taxes from the year of assessment beginning on or after April 1, 2027. Hong Kong and Norway signed a DTA on December 16, 2025, which will reduce Norway's withholding tax on dividends paid to qualifying Hong Kong residents to five or 15 percent (from rates of up to 25 percent under domestic law). On March 2, 2026, Hong Kong signed a DTA with the Kyrgyz Republic, which will reduce the withholding tax rate on dividends paid to qualifying Hong Kong residents to five percent, and will cap withholding tax on interest and royalties received by Hong Kong residents at eight percent. Most recently, on March 19, 2026, Hong Kong signed a DTA with Barbados, under which Barbados will exempt Hong Kong residents from withholding tax on dividends.
As of late April 2026, Hong Kong has 57 CDTAs signed and 51 already in force, reflecting sustained efforts to broaden treaty coverage with both Belt-and-Road and OECD markets.
It is therefore important for foreign investors and expatriates operating through Hong Kong to understand which DTAs exist, and how those agreements apply in practice.
Which countries have signed DTAs with Hong Kong?
Hong Kong operates on a territoriality basis for taxation, only income sourced within Hong Kong is generally subject to tax, meaning Hong Kong residents rarely face double taxation from Hong Kong's side alone. Nevertheless, the Hong Kong SAR government actively pursues comprehensive DTAs with trading partners to clarify tax rights, assist investors in assessing their cross-border tax positions, and serve as an incentive for international business activity.
Hong Kong has signed comprehensive DTAs with 57 countries and regions, of which 51 are in force. The six signed but not yet effective are Barbados, Jordan, the Kyrgyz Republic, the Maldives, Norway, and Rwanda.
| Country / Region | Status |
|---|---|
| Armenia | In Force |
| Austria | In Force |
| Bahrain | In Force |
| Bangladesh | In Force |
| Barbados | Signed — pending ratification |
| Belarus | In Force |
| Belgium | In Force |
| Brunei | In Force |
| Cambodia | In Force |
| Canada | In Force |
| Chinese Mainland | In Force |
| Croatia | In Force |
| Czech Republic | In Force |
| Estonia | In Force |
| Finland | In Force |
| France | In Force |
| Georgia | In Force |
| Guernsey | In Force |
| Hungary | In Force |
| India | In Force |
| Indonesia | In Force |
| Ireland | In Force |
| Italy | In Force |
| Japan | In Force |
| Jersey | In Force |
| Jordan | Signed — pending ratification |
| Korea | In Force |
| Kuwait | In Force |
| Kyrgyz Republic | Signed — pending ratification |
| Latvia | In Force |
| Liechtenstein | In Force |
| Luxembourg | In Force |
| Macao SAR | In Force |
| Malaysia | In Force |
| Maldives | Signed — pending ratification |
| Malta | In Force |
| Mauritius | In Force |
| Mexico | In Force |
| Netherlands | In Force |
| New Zealand | In Force |
| Norway | Signed — pending ratification |
| Pakistan | In Force |
| Portugal | In Force |
| Qatar | In Force |
| Romania | In Force |
| Russia | In Force |
| Rwanda | Signed — pending ratification |
| Saudi Arabia | In Force |
| Serbia | In Force |
| South Africa | In Force |
| Spain | In Force |
| Switzerland | In Force |
| Thailand | In Force |
| Türkiye | In Force (applies from YA 2027/28) |
| United Arab Emirates | In Force |
| United Kingdom | In Force |
| Vietnam | In Force |
"In Force" indicates the DTA has entered into force and is effective from the specified year of assessment. "Signed" indicates the DTA has been signed but has not yet entered into force.
Which countries and regions are still negotiating DTAs with Hong Kong?
Beyond concluded treaties, Hong Kong continues to pursue new negotiations with both established and emerging market partners. Near-term additions to watch include Oman, where first-round negotiations were completed in January 2026, and Slovenia, where first-round negotiations concluded in January 2026. Laos was added to the pipeline in March 2026.
| Country / Region Under Negotiation |
|---|
| Azerbaijan |
| Cabo Verde |
| Cameroon |
| Cyprus |
| Germany |
| Israel |
| Laos |
| Lithuania |
| Mongolia |
| Morocco |
| Nigeria |
| North Macedonia |
| Oman |
| Philippines |
| Slovenia |
| Turkmenistan |
| Ukraine |
| Venezuela |
Hong Kong has also incorporated double taxation relief for airline income into bilateral Air Services Agreements. Similar negotiations are ongoing for shipping income with jurisdictions that do not offer reciprocal tax exemptions.
Who can benefit from Hong Kong's DTAs?
Under most of Hong Kong's DTAs, only Hong Kong residents are eligible to claim treaty benefits. Taxpayers should refer to the protocol of the relevant DTA to confirm whether they qualify.
In general, the following are regarded as Hong Kong residents for DTA purposes:
- An individual who ordinarily resides in Hong Kong;
- An individual who stays in Hong Kong for more than 180 days during a year of assessment, or for more than 300 days across two consecutive years of assessment — one of which is the relevant year of assessment;
- A company, partnership, trust, or body of persons incorporated or constituted in Hong Kong; and
- A company, partnership, trust, or body of persons incorporated or constituted outside Hong Kong but managed or controlled in Hong Kong.
Additionally, Hong Kong offers unilateral tax credit relief to residents who operate businesses in other countries, and many countries with worldwide taxation systems similarly provide their residents operating in Hong Kong with unilateral tax credit relief. Hong Kong also permits a deduction for foreign taxes paid on income that is also subject to Hong Kong taxation, further reducing the practical risk of double taxation for businesses operating in the region.
How do you claim benefits under Hong Kong's DTAs?
To claim DTA benefits, a Hong Kong resident must obtain a Certificate of Resident Status (CoRS) from the Inland Revenue Department (IRD). This certificate serves as official proof of Hong Kong resident status when seeking treaty benefits from a partner jurisdiction, and is issued only after the relevant DTA has become effective.
A CoRS does not guarantee that treaty benefits will be granted — it is ultimately for the treaty partner's tax authority to determine whether all applicable conditions are satisfied. This makes it important for businesses to also align corporate governance and mind-and-management arrangements with their intended residence outcome, particularly in dual-residence cases where tie-breaker analysis may apply.
To apply, the appropriate form must be completed and submitted to the Tax Treaty Section of the IRD. A CoRS is generally issued within 21 working days of receiving a properly completed application.
| DTA Partner | Form (Company / Partnership / Trust / Body of Persons) | Form (Individual) |
|---|---|---|
| Mainland China | IR1313A | IR1314A |
| Other jurisdictions | IR1313B | IR1314B |
Generally, only one CoRS will be issued to an entity per DTA partner per year. For applications relating to the Mainland China–Hong Kong DTA, a CoRS issued for a specific calendar year typically serves as proof of Hong Kong resident status for that year and the two succeeding calendar years.
Authorities increasingly scrutinize treaty claims, especially around beneficial ownership, economic substance, and the timing of income recognition. Businesses should also carefully map dividends, interest, royalties, capital gains, and service fees to the correct treaty articles, and monitor shareholding thresholds for dividend relief, PE triggers for services, and beneficial ownership tests for passive income.
What tax rates apply to dividends, interest, and royalties under Hong Kong's DTAs?
The table below shows the maximum tax rates that countries and regions with comprehensive DTAs with Hong Kong may charge a Hong Kong resident on payments of dividends, interest, royalties, and technical fees. These are maximum treaty rates; if the partner jurisdiction's domestic rate is lower, the lower rate applies. Eligibility often depends on beneficial ownership, shareholding thresholds, and any limitation-on-benefits provisions.
| Country / Region | Effective From (YA) | Dividends (%) | Interest (%) | Royalties (%) | Technical Fees (%) |
|---|---|---|---|---|---|
| Armenia | 2026/27 | 0 / 5 | 5 | 5 | N/A |
| Austria | 2012/13 | 0 / 10 | — | 3 | N/A |
| Bahrain | 2026/27 | — | — | 5 | N/A |
| Bangladesh | 2025/26 | 10 / 15 | 10 | 10 | 10 |
| Barbados | Pending | 0 | — | — | N/A |
| Belarus | 2018/19 | 5 | 5 | 3 / 5 | N/A |
| Belgium | 2004/05 | 0 / 5 / 15 | 10 | 5 | N/A |
| Brunei | 2011/12 | — | 5 / 10 | 5 | 15 |
| Cambodia | 2020/21 | 10 | 10 | 10 | 10 |
| Canada | 2014/15 | 5 / 15 | 10 | 10 | N/A |
| Chinese Mainland | 2007/08 | 5 / 10 | 7 | 5 / 7 | N/A |
| Croatia | 2025/26 | 5 | 5 | 5 | N/A |
| Czech Republic | 2013/14 | 5 | — | 10 | N/A |
| Estonia | 2020/21 | 0 / 10 | 0 / 10 | 5 | N/A |
| Finland | 2019/20 | 5 / 10 | — | 3 | N/A |
| France | 2012/13 | 10 | 10 | 10 | N/A |
| Georgia | 2022/23 | 5 | 5 | 5 | N/A |
| Guernsey | 2014/15 | — | — | 4 | N/A |
| Hungary | 2012/13 | 5 / 10 | 5 | 5 | N/A |
| India | 2019/20 | 5 | 10 | 10 | 10 |
| Indonesia | 2013/14 | 5 / 10 | 10 | 5 | N/A |
| Ireland | 2012/13 | — | 10 | 3 | N/A |
| Italy | 2016/17 | 10 | 12.5 | 15 | N/A |
| Japan | 2012/13 | 5 / 10 | 10 | 5 | N/A |
| Jersey | 2014/15 | — | — | 4 | N/A |
| Korea | 2017/18 | 10 / 15 | 10 | 10 | N/A |
| Kuwait | 2014/15 | 5 | 5 | 5 | N/A |
| Kyrgyz Republic | Pending | 5 | 8 | 8 | N/A |
| Latvia | 2018/19 | 0 / 10 | 0 / 10 | 0 / 3 | N/A |
| Liechtenstein | 2012/13 | — | — | 3 | N/A |
| Luxembourg | 2008/09 | 0 / 10 | — | 3 | N/A |
| Macao SAR | 2021/22 | 5 | 5 | 3 | N/A |
| Malaysia | 2013/14 | 5 / 10 | 10 | 8 | 5 |
| Maldives | Pending | 5 / 10 | 10 | 10 | 10 |
| Malta | 2013/14 | — | — | 3 | N/A |
| Mauritius | 2024/25 | 0 / 5 | 5 | 5 | N/A |
| Mexico | 2014/15 | — | 4.9 / 10 | 10 | N/A |
| Netherlands | 2012/13 | 0 / 10 | — | 3 | N/A |
| New Zealand | 2012/13 | 0 / 5 / 15 | 10 | 5 | N/A |
| Norway | Pending | 5 / 15 | 15 | 5 | N/A |
| Pakistan | 2018/19 | 10 | 10 | 10 | 12.5 |
| Portugal | 2013/14 | 5 / 10 | 10 | 5 | N/A |
| Qatar | 2014/15 | — | — | 5 | N/A |
| Romania | 2017/18 | 3 / 5 | 3 | 3 | N/A |
| Saudi Arabia | 2019/20 | 5 | — | 5 / 8 | N/A |
| Serbia | 2021/22 | 5 / 10 | 10 | 5 / 10 | N/A |
| South Africa | 2016/17 | 5 / 10 | 10 | 5 | N/A |
| Spain | 2013/14 | 0 / 10 | 5 | 5 | N/A |
| Switzerland | 2013/14 | 0 / 10 | — | 3 | N/A |
| Thailand | 2006/07 | 10 | 10 / 15 | 5 / 10 / 15 | N/A |
| Türkiye | 2027/28 | 5 / 10 | 10 | 7.5 / 10 | N/A |
| United Arab Emirates | 2016/17 | 5 | 5 | 5 | N/A |
| United Kingdom | 2011/12 | 0 / 15 | Domestic Rate | 3 | N/A |
| Vietnam | 2010/11 | 10 | 10 | 7 / 10 | N/A |
For the full and authoritative schedule, refer to the IRD's consolidated table of tax rates for dividends, interest, royalties, and technical fees.
How is double taxation eliminated under Hong Kong's DTAs?
The methods of eliminating double taxation are stipulated in the specific DTA or a country’s domestic law.
Tax credit method
In most treaties signed by Hong Kong, residents can avoid double taxation through a tax credit.
Under the credit method, Hong Kong SAR shall grant credit for the tax paid in a foreign jurisdiction outside of Hong Kong regarding income derived by a person who is a resident of the Hong Kong SAR from sources of that foreign jurisdiction.
However, the credit should not exceed the amount of Hong Kong SAR’s tax computed for that income following the tax laws.
Tax exemption method
In addition to tax credit relief, double taxation can be eliminated by tax exemption methods, reduced tax rates, as well as relief by deductions. However, these methods are not used as commonly as the tax credit method.
What is an Advance Pricing Agreement?
Hong Kong’s onshore-offshore tax regime often reduces the tax burden for those who operate through Hong Kong companies by pricing intra-group transactions. This has led to heightened transfer pricing scrutiny from the Hong Kong Inland Revenue Department in recent years.
Consequently, the Advance Pricing Arrangement (APA) program was introduced to Hong Kong. It was widely regarded as a welcome development for multinational companies, as it offers a non-adversarial approach in which taxpayers can transparently engage with tax authorities to achieve an optimal tax outcome.
An APA is an agreement that determines an appropriate set of criteria (e.g., transfer pricing method, external data, reasonable adjustments, critical assumptions as to future events) to determine the pricing of related party transactions over a fixed period. This is either three or five years.
Hong Kong can only start an APA program with another country after signing a DTA with the concerned country.
