Notes to Tax Rates for Dividends, Interest, Royalties and Technical Fees

Qualifying Companies
Refer to Article 10 of the relevant Comprehensive Double Taxation Agreement / Arrangement to see whether the company is qualified for the special rate.
Interest
Exemption is granted to the interest paid to specified bodies and institutions. Such exemptions are not considered in this column.
The symbol “-” represents that the country / region does not have any taxing right on the dividends and / or interest.
The abbreviation “NA” means no technical fees article.

Notes for country / region having more than one rate

Notes to Tax Rates for Dividends, Interest, Royalties and Technical Fees
Armenia Mauritius	Dividends (Qualifying Companies) 0% applies if the beneficial owner of the dividends is a company which holds directly at least 10% of the payer’s capital throughout a 365 day period that includes the day of the payment of the dividends. Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any entity wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. Interest Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any entity wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed.
Austria Canada Finland Hungary Japan Luxembourg Malaysia Netherlands Portugal South Africa Switzerland	Dividends (Qualifying Companies) Generally, this rate applies if the beneficial owner of the dividends is a company that holds / controls directly or indirectly at least 10% of the payer’s capital or voting power.
Bangladesh	Dividends (Qualifying Companies) 10% applies if the beneficial owner of the dividends is a company which holds directly at least 10% of the payer’s capital. Interest Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any entity wholly owned by the Government of the Hong Kong Special Administrative Region as agreed.
Belarus	Dividends Dividends are exempt from tax if the beneficial owner of the dividends is: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. Interest Interest is exempt from tax if the beneficial owner of the interest is: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. Royalties 3% applies to payments for the use of, or the right to use aircraft. 5% applies in all other cases.
Belgium	Dividends (Qualifying Companies) Dividends shall not be taxed if the beneficial owner of the dividends is a company that holds directly at least 25% of the payer’s capital for an uninterrupted period of at least 12 months. 5% applies if the beneficial owner of the dividends is a company which holds directly at least 10% of the payer’s capital.
Brunei	Interest 5% applies if the interest is received by any bank or financial institution. 10% applies in all other cases.
Cambodia	Interest Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) a financial establishment appointed by the Government of the Hong Kong Special Administrative Region as agreed.
Croatia Georgia	Dividends Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any entity wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. Interest Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any entity wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed.
Estonia	Dividends (Qualifying Companies) 0% applies if the beneficial owner of the dividends is a company. Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. Interest 0% applies if the beneficial owner of the interest is a company. 10% applies in all other cases. Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed.
Indonesia Korea Spain	Dividends (Qualifying Companies) This rate applies if the beneficial owner of the dividends is a company that holds directly at least 25% of the payer’s capital.
Kuwait United Arab Emirates	Dividends 0% applies if the beneficial owner of the dividends is the Government of the Hong Kong Special Administrative Region or any of its institutions or other entity wholly-owned directly by the Government of the Hong Kong Special Administrative Region.
Latvia	Dividends (Qualifying Companies) 0% applies if the beneficial owner of the dividends is a company (other than a partnership). Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. Interest 0% applies if the beneficial owner of the interest is a company (other than a partnership). 10% applies in all other cases. Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. Royalties 0% of the gross amount of the royalties for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience applies if the beneficial owner of the royalties is a company (other than a partnership). 3% applies in all other cases.
Macao SAR	Dividends Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed between the competent authorities of both sides. Interest Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed between the competent authorities of both sides.
Mainland of China	Dividends (Qualifying Companies) 5% applies if the beneficial owner of the dividends is a company that holds directly at least 25% of the payer’s capital. Royalties With effect from 29.12.2015, 5% applies for royalties paid to an aircraft and ship leasing business. 7% applies in all other cases.
Mexico	Interest 4.9% applies if the beneficial owner of the interest is a bank. 10% applies in all other cases.
New Zealand	Dividends (Qualifying Companies) Dividends shall not be taxed if the beneficial owner is a company that holds directly or indirectly at least 50% of the payer’s voting power, and meets specified requirements. Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; or (c) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. 5% applies if the beneficial owner of the dividends is a company which holds directly at least 10% of the payer’s voting power.
Pakistan	Interest Interest shall be exempt from tax if it is beneficially owned by (a) the Hong Kong Monetary Authority; (b) the Exchange Fund; (c) the Government of the Hong Kong Special Administrative Region; or (d) any entity wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed.
Romania	Dividends (Qualifying Companies) This rate applies if the beneficial owner of the dividends is a company (other than partnership) which holds directly at least 15% of the payer’s capital. Dividends are exempt from tax if they are derived and beneficially owned by: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) a financial institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed. Interest 0% applies if and as long as the Hong Kong Special Administrative Region levies no withholding tax on interest. Interest is exempt from tax if it is derived and beneficially owned by (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) a financial institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed.
Russia	Dividends (Qualifying Companies) 5% applies if the beneficial owner of the dividends is a company (other than a partnership) which holds directly at least 15% of the payer’s capital. Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange fund; or (d) any entity wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed.
Saudi Arabia	Royalties 5% applies to payments for the use of, or the right to use, industrial, commercial or scientific equipment. 8% applies in all other cases.
Serbia	Dividends (Qualifying Companies) 5% applies if the beneficial owner of the dividends is a company which holds directly at least 25% of the payer’s capital throughout a 365 day period that includes the day of the payment of the dividends. Royalties 5% applies to payments for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films or films or tapes used for radio or television broadcasting. 10% applies to payments for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for the use of or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
Thailand	Interest 10% applies if the interest is beneficially owned by (a) any financial institution or insurance company; or (b) a resident of the Hong Kong Special Administrative Region and is paid with respect to indebtedness arising as a consequence of a sale on credit by a resident of the Hong Kong Special Administrative Region of any equipment, merchandise or services, except where the sale was between persons not dealing with each other at arm’s length. 15% applies in all other cases. Royalties 5% applies to payments for the use of, or the right to use, any copyright of literary, artistic or scientific work. 10% applies to payments for the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process. 15% applies in all other cases.
Türkiye	Dividends (Qualifying Companies) 5% applies if the beneficial owner of the dividends is a company (other than a partnership) which holds directly at least 25% of the payer’s capital throughout a 365 day period that includes the day of the payment of the dividends. Interest 7.5% applies if the interest is received by a financial institution in respect of a loan or debt instrument with a maturity period exceeding 2 years. 10% applies in all other cases. Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; or (c) the Exchange Fund. Royalties 7.5% applies to payments for the use of, or the right to use, industrial, commercial or scientific equipment. 10% applies in all other cases.
United Kingdom	Dividends 15% applies if, other than where the beneficial owner of the dividends is a pension scheme, dividends are paid out of income (including gains) derived directly or indirectly from immovable property within the meaning of Article 6 by an investment vehicle which distributes most of this income annually and whose income from such immovable property is exempted from tax. Dividends shall be exempt from tax in all other cases. Interest The domestic rate generally applies. There is no withholding tax where (a) the interest is beneficially owned by (i) the Government of the Hong Kong Special Administrative Region including the Hong Kong Monetary Authority; (ii) an individual; (iii) a listed company; (iv) a pension scheme; (v) a financial institution which is unrelated to and dealing wholly independently with the payer; or (vi) any other company which was accepted that its establishment, acquisition or maintenance does not have as its main purpose or one of its main purposes to secure the benefits of the article on interest; or (b) the interest is paid: (i) by the Government of the Hong Kong Special Administrative Region including the Hong Kong Monetary Authority; (ii) by a bank in the ordinary course of its banking business; or (iii) on a quoted Eurobond.
Vietnam	Royalties 7% applies to payments for the use of, or the right to use, any patent, design or model, plan, secret formula or process. 10% applies in all other cases.