Соглашение об избежании двойного налогообложения: Гонконг — Индия: ответы с источниками

5

YA 2019/2020

«Article 12 Royalties 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise, and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration 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 television or radio broadcasting, 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. 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

«Article 10 Dividends 1. Dividends paid by a company which is a resident of a Contracting Party to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such dividends may also be taxed in the Contracting Party of which the company paying the dividends is a resident and according to the laws of that Party, but if the beneficial owner of the dividends is a resident of the other Contracting Party, the tax so charged shall not exceed 5 per cent of the gross amount of the dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The term “dividends” as used in this Article means income from shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Party of which the company making the distribution is a resident. 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

«India Year of Assessment 2019/2020 5 10 10 10 Indonesia Year of Assessment 2013/2014 5 10 10 5 NA»

Источник: ird.gov.hk · копия источника от 2026-10-03

«The following table shows the maximum rates of tax those countries / regions with a Comprehensive Double Taxation Agreement / Arrangement with the Hong Kong Special Administrative Region (Hong Kong) can charge a Hong Kong resident on payments of dividends, interest, royalties and technical fees. Country / Region Effective From Dividends Interest (%) Royalties (%) Technical Fees (%) Qualifying Companies (%) Others (%) Armenia Year of Assessment 2026/2027 0 5 5 5 NA Austria Year of Assessment 2012/2013 0 10 - 3 NA Bahrain Year of Assessment 2026/2027 - - 5 NA Bangladesh Year of Assessment 2025/2026 10 15 10 10 10 Barbados Pending - 5 3/5 NA Belarus Year of Assessment 2018/2019 5 5 3/5 NA Belgi»

Источник: ird.gov.hk · копия источника от 2026-10-03

«Article 11 Interest 1. Interest arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such interest may also be taxed in the Contracting Party in which it arises and according to the laws of that Party, but if the beneficial owner of the interest is a resident of the other Contracting Party, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting Party shall be exempt from tax in that Party provided that it is derived and beneficially owned by: (a) the Government, a political subdivision or a local authority of the other Contracting Party; or (b) (i) in the case of the Hong Kong Special Administrative Region, the Hong Kong Monetary Authority and the Exchange Fund; (ii) in the case of India, the Reserve Bank of India and the Export-Import Bank of India; or (c) any other institution as may be agreed upon from time to time between the competent authorities of the Contracting Parties. 1 Refer to the box following paragraph 2 of Article 28 of the Agreement. 18 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

10

YA 2019/2020

«Article 12 Royalties 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise, and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration 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 television or radio broadcasting, 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. 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

«Article 10 Dividends 1. Dividends paid by a company which is a resident of a Contracting Party to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such dividends may also be taxed in the Contracting Party of which the company paying the dividends is a resident and according to the laws of that Party, but if the beneficial owner of the dividends is a resident of the other Contracting Party, the tax so charged shall not exceed 5 per cent of the gross amount of the dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The term “dividends” as used in this Article means income from shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Party of which the company making the distribution is a resident. 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

«India Year of Assessment 2019/2020 5 10 10 10 Indonesia Year of Assessment 2013/2014 5 10 10 5 NA»

Источник: ird.gov.hk · копия источника от 2026-10-03

«The following table shows the maximum rates of tax those countries / regions with a Comprehensive Double Taxation Agreement / Arrangement with the Hong Kong Special Administrative Region (Hong Kong) can charge a Hong Kong resident on payments of dividends, interest, royalties and technical fees. Country / Region Effective From Dividends Interest (%) Royalties (%) Technical Fees (%) Qualifying Companies (%) Others (%) Armenia Year of Assessment 2026/2027 0 5 5 5 NA Austria Year of Assessment 2012/2013 0 10 - 3 NA Bahrain Year of Assessment 2026/2027 - - 5 NA Bangladesh Year of Assessment 2025/2026 10 15 10 10 10 Barbados Pending - 5 3/5 NA Belarus Year of Assessment 2018/2019 5 5 3/5 NA Belgi»

Источник: ird.gov.hk · копия источника от 2026-10-03

«Article 11 Interest 1. Interest arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such interest may also be taxed in the Contracting Party in which it arises and according to the laws of that Party, but if the beneficial owner of the interest is a resident of the other Contracting Party, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting Party shall be exempt from tax in that Party provided that it is derived and beneficially owned by: (a) the Government, a political subdivision or a local authority of the other Contracting Party; or (b) (i) in the case of the Hong Kong Special Administrative Region, the Hong Kong Monetary Authority and the Exchange Fund; (ii) in the case of India, the Reserve Bank of India and the Export-Import Bank of India; or (c) any other institution as may be agreed upon from time to time between the competent authorities of the Contracting Parties. 1 Refer to the box following paragraph 2 of Article 28 of the Agreement. 18 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

10

YA 2019/2020

«Article 12 Royalties 1. Royalties arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise, and according to the laws of that Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. 3. The term “royalties” as used in this Article means payments of any kind received as a consideration 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 television or radio broadcasting, 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. 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

«Article 10 Dividends 1. Dividends paid by a company which is a resident of a Contracting Party to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such dividends may also be taxed in the Contracting Party of which the company paying the dividends is a resident and according to the laws of that Party, but if the beneficial owner of the dividends is a resident of the other Contracting Party, the tax so charged shall not exceed 5 per cent of the gross amount of the dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 3. The term “dividends” as used in this Article means income from shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the Party of which the company making the distribution is a resident. 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03

«India Year of Assessment 2019/2020 5 10 10 10 Indonesia Year of Assessment 2013/2014 5 10 10 5 NA»

Источник: ird.gov.hk · копия источника от 2026-10-03

«The following table shows the maximum rates of tax those countries / regions with a Comprehensive Double Taxation Agreement / Arrangement with the Hong Kong Special Administrative Region (Hong Kong) can charge a Hong Kong resident on payments of dividends, interest, royalties and technical fees. Country / Region Effective From Dividends Interest (%) Royalties (%) Technical Fees (%) Qualifying Companies (%) Others (%) Armenia Year of Assessment 2026/2027 0 5 5 5 NA Austria Year of Assessment 2012/2013 0 10 - 3 NA Bahrain Year of Assessment 2026/2027 - - 5 NA Bangladesh Year of Assessment 2025/2026 10 15 10 10 10 Barbados Pending - 5 3/5 NA Belarus Year of Assessment 2018/2019 5 5 3/5 NA Belgi»

Источник: ird.gov.hk · копия источника от 2026-10-03

«Article 11 Interest 1. Interest arising in a Contracting Party and paid to a resident of the other Contracting Party may be taxed in that other Party. 2. However, such interest may also be taxed in the Contracting Party in which it arises and according to the laws of that Party, but if the beneficial owner of the interest is a resident of the other Contracting Party, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. 3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting Party shall be exempt from tax in that Party provided that it is derived and beneficially owned by: (a) the Government, a political subdivision or a local authority of the other Contracting Party; or (b) (i) in the case of the Hong Kong Special Administrative Region, the Hong Kong Monetary Authority and the Exchange Fund; (ii) in the case of India, the Reserve Bank of India and the Export-Import Bank of India; or (c) any other institution as may be agreed upon from time to time between the competent authorities of the Contracting Parties. 1 Refer to the box following paragraph 2 of Article 28 of the Agreement. 18 4. …»

Источник: ird.gov.hk · копия источника от 2026-10-03