Treaty detail
China - Hong Kong tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2006-08-21
Effective
2006-12-08
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 5%
The arrangement provides a 5 percent rate for qualifying corporate shareholders with direct ownership of at least 25 percent. The 10 percent rate applies otherwise.
Interest
Rate: 7%
The 7 percent ceiling can be reduced to zero for qualifying government interest under the arrangement.
Royalties
Rate: 7%
Royalties generally face a 7 percent ceiling under the arrangement, with reductions for certain categories.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis under the arrangement includes specified habitual-conclusion rules.
Other treaty flags
Pension treatment is article-specific under the arrangement.
Seeded article summaries
Article 4
Residence
Defines residence under the Mainland-Hong Kong arrangement.
Article 4 reflects the unique nature of this arrangement, which is an internal-China DTA between the mainland tax authorities and Hong Kong as a Special Administrative Region rather than an inter-state treaty.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The arrangement includes both construction and service-PE rules under the 2006 wording as amended.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 is the operating rule for cross-border services between the mainland and Hong Kong.
Article 10
Dividends
Caps source-country dividend withholding at arrangement ceilings.
Article 10 produces the 10 percent and 5 percent ceilings under the arrangement.
Article 11
Interest
Limits source-country withholding on qualifying interest to a 7 percent ceiling.
Article 11 produces a 7 percent ceiling with carve-outs for qualifying government interest.
Article 12
Royalties
Caps royalties at a 7 percent ceiling.
Article 12 limits royalties at 7 percent generally with reductions for certain categories.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–CN treaty
- TreatyGB–CN treaty
- TreatyCA–CN treaty
- TreatyAU–CN treaty
- TreatyCN–DE treaty
- TreatyCN–JP treaty
- TreatyCN–IN treaty
- TreatyCN–SG treaty
Primary sources
- Hong Kong IRD: comprehensive double taxation agreementsVerified 2026-05-20
- State Taxation Administration of ChinaVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.