A first-time comprehensive Double Taxation Agreement (CDTA) between the United Kingdom and the Hong Kong Special Administrative Region of the People’s Republic of China was signed in London on 21 June 2010.
The Agreement generally follows the OECD Model Double Taxation Convention. Important features include:
- the latest OECD provision on exchange of information, but limited to taxes covered by the Agreement
- zero rate of withholding tax on dividends (except for REITs) and 3 per cent on royalties
- zero rate of withholding tax on interest but with a provision to ensure the benefits of the interest article can only flow to residents of the other state.
The text of the new Agreement is available on HM Revenue & Customs' website, and will be published by the Stationery Office as soon as it is presented to Parliament for approval.