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Comprehensive Double Taxation Agreements

Hong Kong has entered into Comprehensive Double Taxation Agreements / Arrangement (DTAs) with a number of jurisdictions.  DTAs are also referred to as tax treaties.  They prevent double taxation and fiscal evasion, and foster cooperation between Hong Kong and other international tax administrations by enforcing their respective tax laws.  You will only be affected by a DTA if you are a resident of Hong Kong or the other DTA jurisdiction.

Generally, Hong Kong's DTAs operate to:

  • reduce or eliminate double taxation caused by overlapping tax jurisdictions;
  • provide a level of security about the tax rules that will apply to particular international transactions by -
    • allocating taxing rights between the jurisdictions over different categories of income,
    • specifying rules to resolve conflicting claims about the residential status of a taxpayer and the source of income,
    • providing an avenue for a taxpayer to present a case to the relevant tax administrations if a taxpayer considers there has been taxation treatment contrary to the terms of a DTA;
  • prevent avoidance and evasion of taxes on various forms of income flows between Hong Kong and the DTA partners by -
    • providing for the allocation of profits between associated enterprises on an arm’s length basis,
    • providing for exchange of information between the respective tax administrations;
  • facilitate investment, trade, movement of technology, and movement of personnel by reducing rates of foreign withholding tax.

Hong Kong has actively engaged the trading partners in negotiating DTAs.  Please click below links for more information on: