Double tax treaty: Hong Kong — Luxembourg: sourced answers
1 answer to specific questions — each with a verbatim quote from an official source and a link to it.
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Tax treaty or act
What maximum withholding tax rate on royalties does the agreement set
3
YA 2008/2009
«Luxembourg 02.11.2007 22.01.2008 20.01.2009 Year of Assessment 2008/2009 BA Yes Yes Protocol: 11.11.2010 03.05.2011 17.08.2011 Year of Assessment 2012/2013 BA Macao SAR 22.11.2019 and 25.11.2019 12.05.2020 18.08.2020 Year of Assessment 2021/2022 DK N»
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. 18 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, or films or tapes used for radio or television 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. …»
Source: ird.gov.hk · source copy as of 2026-10-03
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