Double tax treaty: Hong Kong — Russia: sourced answers
6 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
When did the agreement or act enter into force
the agreement with Russia entered into force on 29 July 2016
«sessment 2014/2015 CJ Yes Yes Romania 18.11.2015 26.04.2016 21.11.2016 Income derived on or after 01.01.2017 CV Yes Yes Russia 18.01.2016 26.04.2016 29.07.2016 Year of Assessment 2017/2018 CW Yes Yes Rwanda (see note 17 ) 09.10.2025 In progress Pending Pending - N/A N/A Saudi Arabia 24.08.2017 08.05.2018 01.09.2018 Year of Assessment 2019/2020 DB Yes Yes Serbia 14.08.2020 and 27.08.2020 20.10.2020 30.12.2020 Year of Assessment 2021/2022 DM N/A N/A Slovenia (see note 18 ) 04.09.2026»
Source: ird.gov.hk · source copy as of 2026-10-02
«and Exchange of Information Arrangements > All Agreement (on country / region basis) > Russia Russia Russian Federation - Russia Nature Comprehensive Double Taxation Agreement Air Services Income Agreement Date of Signature of Agreement 18.01.2016 22.01.1999 Date of S49 Order 26.04.2016 11.05.1999 Date of Entry into Force 29.07.2016 01.06.2010 Effective From Year of Assessment 2017/2018 Year of Assessment 2011/2012 IRO Sub-legislation Reference CW Y back to top»
Source: ird.gov.hk · source copy as of 2026-10-03
«avoidance, whether or not described as such. Article 28 Entry into Force 1. Each of the Contracting Parties shall notify the other in writing of the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of the Agreement shall thereupon have effect: (a) in the Hong Kong Special Administrative Region: in respect of Hong Kong Special Administrative Region tax, for any taxable periods beginning on or after 1 April in the calendar year next following that in which the Agreement enters into force; (b) in Russia: in respect of Russian tax, for any taxable periods beginning on or after 1 January in the calendar year next following that in which the Agreement enters into force. 3. …»
Source: ird.gov.hk · source copy as of 2026-10-03
in force since 29 July 2016
«sessment 2014/2015 CJ Yes Yes Romania 18.11.2015 26.04.2016 21.11.2016 Income derived on or after 01.01.2017 CV Yes Yes Russia 18.01.2016 26.04.2016 29.07.2016 Year of Assessment 2017/2018 CW Yes Yes Rwanda (see note 17 ) 09.10.2025 In progress Pending Pending - N/A N/A Saudi Arabia 24.08.2017 08.05.2018 01.09.2018 Year of Assessment 2019/2020 DB Yes Yes Serbia 14.08.2020 and 27.08.2020 20.10.2020 30.12.2020 Year of Assessment 2021/2022 DM N/A N/A Slovenia (see note 18 ) 04.09.2026»
Source: ird.gov.hk · source copy as of 2026-10-02
«and Exchange of Information Arrangements > All Agreement (on country / region basis) > Russia Russia Russian Federation - Russia Nature Comprehensive Double Taxation Agreement Air Services Income Agreement Date of Signature of Agreement 18.01.2016 22.01.1999 Date of S49 Order 26.04.2016 11.05.1999 Date of Entry into Force 29.07.2016 01.06.2010 Effective From Year of Assessment 2017/2018 Year of Assessment 2011/2012 IRO Sub-legislation Reference CW Y back to top»
Source: ird.gov.hk · source copy as of 2026-10-03
«avoidance, whether or not described as such. Article 28 Entry into Force 1. Each of the Contracting Parties shall notify the other in writing of the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of the Agreement shall thereupon have effect: (a) in the Hong Kong Special Administrative Region: in respect of Hong Kong Special Administrative Region tax, for any taxable periods beginning on or after 1 April in the calendar year next following that in which the Agreement enters into force; (b) in Russia: in respect of Russian tax, for any taxable periods beginning on or after 1 January in the calendar year next following that in which the Agreement enters into force. 3. …»
Source: ird.gov.hk · source copy as of 2026-10-03
Entered into force 2016-07-29 (effective YA 2017/18; MLI modified)
«sessment 2014/2015 CJ Yes Yes Romania 18.11.2015 26.04.2016 21.11.2016 Income derived on or after 01.01.2017 CV Yes Yes Russia 18.01.2016 26.04.2016 29.07.2016 Year of Assessment 2017/2018 CW Yes Yes Rwanda (see note 17 ) 09.10.2025 In progress Pending Pending - N/A N/A Saudi Arabia 24.08.2017 08.05.2018 01.09.2018 Year of Assessment 2019/2020 DB Yes Yes Serbia 14.08.2020 and 27.08.2020 20.10.2020 30.12.2020 Year of Assessment 2021/2022 DM N/A N/A Slovenia (see note 18 ) 04.09.2026»
Source: ird.gov.hk · source copy as of 2026-10-02
«and Exchange of Information Arrangements > All Agreement (on country / region basis) > Russia Russia Russian Federation - Russia Nature Comprehensive Double Taxation Agreement Air Services Income Agreement Date of Signature of Agreement 18.01.2016 22.01.1999 Date of S49 Order 26.04.2016 11.05.1999 Date of Entry into Force 29.07.2016 01.06.2010 Effective From Year of Assessment 2017/2018 Year of Assessment 2011/2012 IRO Sub-legislation Reference CW Y back to top»
Source: ird.gov.hk · source copy as of 2026-10-03
«SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING AND THE AGREEMENT BETWEEN THE GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION OF THE PEOPLE’S REPUBLIC OF CHINA AND THE GOVERNMENT OF THE RUSSIAN FEDERATION FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME General disclaimer on the synthesised text document This document presents the synthesised text for the application of the Agreement between the Government of the Hong Kong Special Administrative Region of the People’s Republic of China and the Government of the Russian Federation for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 18 January 2016 (the “Agreement”), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the People’s Republic of China and the Russian Federation on 7 June 2017 (the “MLI”). …»
Source: ird.gov.hk · source copy as of 2026-10-03
«avoidance, whether or not described as such. Article 28 Entry into Force 1. Each of the Contracting Parties shall notify the other in writing of the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of the Agreement shall thereupon have effect: (a) in the Hong Kong Special Administrative Region: in respect of Hong Kong Special Administrative Region tax, for any taxable periods beginning on or after 1 April in the calendar year next following that in which the Agreement enters into force; (b) in Russia: in respect of Russian tax, for any taxable periods beginning on or after 1 January in the calendar year next following that in which the Agreement enters into force. 3. …»
Source: ird.gov.hk · source copy as of 2026-10-03
From what date do the provisions of the agreement or act apply
1 January 2017 in Russia, from the 2017/18 year of assessment in Hong Kong; in force since 29 July 2016
«and Exchange of Information Arrangements > All Agreement (on country / region basis) > Russia Russia Russian Federation - Russia Nature Comprehensive Double Taxation Agreement Air Services Income Agreement Date of Signature of Agreement 18.01.2016 22.01.1999 Date of S49 Order 26.04.2016 11.05.1999 Date of Entry into Force 29.07.2016 01.06.2010 Effective From Year of Assessment 2017/2018 Year of Assessment 2011/2012 IRO Sub-legislation Reference CW Y back to top»
Source: ird.gov.hk · source copy as of 2026-10-03
«avoidance, whether or not described as such. Article 28 Entry into Force 1. Each of the Contracting Parties shall notify the other in writing of the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of the Agreement shall thereupon have effect: (a) in the Hong Kong Special Administrative Region: in respect of Hong Kong Special Administrative Region tax, for any taxable periods beginning on or after 1 April in the calendar year next following that in which the Agreement enters into force; (b) in Russia: in respect of Russian tax, for any taxable periods beginning on or after 1 January in the calendar year next following that in which the Agreement enters into force. 3. …»
Source: ird.gov.hk · source copy as of 2026-10-03
1 January 2017 in Russia
from the 2017/18 year of assessment in Hong Kong
«and Exchange of Information Arrangements > All Agreement (on country / region basis) > Russia Russia Russian Federation - Russia Nature Comprehensive Double Taxation Agreement Air Services Income Agreement Date of Signature of Agreement 18.01.2016 22.01.1999 Date of S49 Order 26.04.2016 11.05.1999 Date of Entry into Force 29.07.2016 01.06.2010 Effective From Year of Assessment 2017/2018 Year of Assessment 2011/2012 IRO Sub-legislation Reference CW Y back to top»
Source: ird.gov.hk · source copy as of 2026-10-03
«avoidance, whether or not described as such. Article 28 Entry into Force 1. Each of the Contracting Parties shall notify the other in writing of the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications. 2. The provisions of the Agreement shall thereupon have effect: (a) in the Hong Kong Special Administrative Region: in respect of Hong Kong Special Administrative Region tax, for any taxable periods beginning on or after 1 April in the calendar year next following that in which the Agreement enters into force; (b) in Russia: in respect of Russian tax, for any taxable periods beginning on or after 1 January in the calendar year next following that in which the Agreement enters into force. 3. …»
Source: ird.gov.hk · source copy as of 2026-10-03
What maximum withholding tax rate on interest does the agreement set
0%
«n or assignment.] Article 11 Interest 1. Interest arising in a Contracting Party and paid to a resident of the other Contracting Party shall be taxable only by that other Party. 2. The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor’s profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article. 3. The provisions of paragraph 1 shall not apply if the beneficial owner of the interest, being a resident of a Contracting Party, carries on business in the other Contracting Party in which the interest arises, through a permanent establishment situated therein, or performs in that other Party independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. …»
Source: ird.gov.hk · source copy as of 2026-10-03
«cle 13 of this Agreement: ARTICLE 7 OF THE MLI – PREVENTION OF TREATY ABUSE (Principal purposes test provision) Notwithstanding any provisions of this Agreement, a benefit under the Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the Agreement. 30 Article 27 Anti-Abuse Measures Nothing in this Agreement shall prejudice the right of each Contracting Party to apply its internal laws and measures concerning tax avoidance, whether or not described as such. Article 28 Entry into For»
Source: ird.gov.hk · source copy as of 2026-10-03
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