Double tax treaty: Hong Kong — Ireland: sourced answers
2 answers to specific questions — each with a verbatim quote from an official source and a link to it.
Every answer is checked against a verbatim quote from a stored copy of its source and has passed an independent review. This is reference information, not legal advice: rules change, and the outcome depends on your circumstances.
Tax treaty or act
What maximum withholding tax rate on interest does the agreement set
10
YA 2012/2013
«Ireland (see note 8 ) 22.06.2010 28.09.2010 10.02.2011 Year of Assessment 2012/2013 BQ Yes Yes Italy 14.01.2013 24.09.2013 10.08.2015 Year of Assessment 2016/2017 CI Pending Pending Japan (see note 9 ) 09.11.2010 12.04.2011 14.08.2011 Year of Assessm»
Source: ird.gov.hk · source copy as of 2026-10-02
«Article 11 INTEREST 1. Interest arising in a Contracting Party and paid to a resident in 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 in force in that Party, but if the beneficial owner of the interest is a resident in the other Contracting 16 Party, the tax so charged shall not exceed 10 per cent of the gross amount of the interest. The competent authorities of the Contracting Parties shall by mutual agreement settle the mode of application of this limitation. 3. Notwithstanding the provisions of paragraph 2, interest referred to in paragraph 1 shall be taxable only in the Contracting Party of which the recipient is a resident if the beneficial owner of the interest is a resident of that Party and: (a) in the case of Ireland is the Government or is: (i) the Central Bank of Ireland; (ii) the National Treasury Management Agency; (iii) the National Pension Reserve Fund; (iv) the National Assets Management Agency; …»
Source: ird.gov.hk · source copy as of 2026-10-03
What maximum withholding tax rate on royalties does the agreement set
3
YA 2012/2013
«Ireland (see note 8 ) 22.06.2010 28.09.2010 10.02.2011 Year of Assessment 2012/2013 BQ Yes Yes Italy 14.01.2013 24.09.2013 10.08.2015 Year of Assessment 2016/2017 CI Pending Pending Japan (see note 9 ) 09.11.2010 12.04.2011 14.08.2011 Year of Assessm»
Source: ird.gov.hk · source copy as of 2026-10-02
«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 3 per cent of the gross amount of the royalties. The competent authorities of the Contracting Parties shall by mutual agreement settle the mode of application of this limitation. 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 and recordings on tape or other media used for radio or television broadcasting or other means of reproduction or transmission), any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience. 4. …»
Source: ird.gov.hk · source copy as of 2026-10-03
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