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Double tax treaty: Hong Kong — Macao: sourced answers

3 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 dividends does the agreement set

5

YA 2021/2022

«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»

Source: ird.gov.hk · source copy as of 2026-10-03

«Macao SAR Year of Assessment 2021/2022 5 5 3 NA»

Source: ird.gov.hk · source copy as of 2026-10-03

«Macao SAR Dividends Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed between the competent authorities of both sides. Interest Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed between the competent authorities of both sides. Maldives Dividends (Qualifying Companies) 5% applies if the beneficial owner of the dividends is a company which holds directly at least 25% of the payer’s capital throughout a 365 day period that includes the day of the payment of the dividend. Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; …»

Source: ird.gov.hk · source copy as of 2026-10-03

What maximum withholding tax rate on interest does the agreement set

5

YA 2021/2022

«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»

Source: ird.gov.hk · source copy as of 2026-10-03

«Macao SAR Year of Assessment 2021/2022 5 5 3 NA»

Source: ird.gov.hk · source copy as of 2026-10-03

«Macao SAR Dividends Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed between the competent authorities of both sides. Interest Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed between the competent authorities of both sides. Maldives Dividends (Qualifying Companies) 5% applies if the beneficial owner of the dividends is a company which holds directly at least 25% of the payer’s capital throughout a 365 day period that includes the day of the payment of the dividend. Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; …»

Source: ird.gov.hk · source copy as of 2026-10-03

What maximum withholding tax rate on royalties does the agreement set

3

YA 2021/2022

«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»

Source: ird.gov.hk · source copy as of 2026-10-03

«Macao SAR Year of Assessment 2021/2022 5 5 3 NA»

Source: ird.gov.hk · source copy as of 2026-10-03

«Macao SAR Dividends Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed between the competent authorities of both sides. Interest Interest is exempt from tax if it is paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; or (d) any institution wholly or mainly owned by the Government of the Hong Kong Special Administrative Region as agreed between the competent authorities of both sides. Maldives Dividends (Qualifying Companies) 5% applies if the beneficial owner of the dividends is a company which holds directly at least 25% of the payer’s capital throughout a 365 day period that includes the day of the payment of the dividend. Dividends are exempt from tax if they are paid to: (a) the Government of the Hong Kong Special Administrative Region; (b) the Hong Kong Monetary Authority; (c) the Exchange Fund; …»

Source: ird.gov.hk · source copy as of 2026-10-03

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