Double tax treaty: Hong Kong — Japan: 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
«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 Contracting Party. 2. However, such interest may also be taxed in the Contracting Party in which it arises and according to the laws of that Contracting 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 taxable only in the other Contracting Party if: (a) the interest is beneficially owned by the Government of that other Contracting Party, a political subdivision or local authority thereof, or the central bank of that other Contracting Party or any institution wholly owned or funded by that Government; …»
Source: ird.gov.hk · source copy as of 2026-10-03
«Japan (see note 9 ) 09.11.2010 12.04.2011 14.08.2011 Year of Assessment 2012/2013 BS Yes Yes Exchange of Notes: 10.12.2014 (see note 10 ) 12.05.2015 06.07.2015 Year of Assessment 2016/2017 BS Jersey 15.02.2012 and 22.02.2012 23.04.2013 03.07.2013 Yea»
Source: ird.gov.hk · source copy as of 2026-10-02
What maximum withholding tax rate on royalties does the agreement set
5
YA 2012/2013
«Japan (see note 9 ) 09.11.2010 12.04.2011 14.08.2011 Year of Assessment 2012/2013 BS Yes Yes Exchange of Notes: 10.12.2014 (see note 10 ) 12.05.2015 06.07.2015 Year of Assessment 2016/2017 BS Jersey 15.02.2012 and 22.02.2012 23.04.2013 03.07.2013 Yea»
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 Contracting Party. 2. However, such royalties may also be taxed in the Contracting Party in which they arise and according to the laws of that Contracting Party, but if the beneficial owner of the royalties is a resident of the other Contracting Party, the tax so charged shall not exceed 5 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 and films or tapes for radio or television broadcasting, any patent, trade mark, design or model, plan, or 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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