On 29 October 2026, the Government of the Hong Kong Special Administrative Region and the Government of the Lao People’s Democratic Republic signed a Comprehensive Avoidance of Double Taxation Agreement (CDTA) in Hong Kong. Per the official press release, this is Hong Kong’s 61st CDTA, the 6th this year, and the 16th under the current-term Government. Hong Kong now has CDTAs with seven ASEAN members, covering more than 70% of ASEAN’s population and GDP. This note summarises public IRD materials — general information only, not tax advice.
The agreement is not yet in force. It needs ratification by both sides. In Hong Kong, the Chief Executive in Council must make an order under the Inland Revenue Ordinance, then table it at the Legislative Council for negative vetting. The IRD Laos page currently shows: signed 29.10.2026; Cap. 49 order “in progress”; effective date “to be confirmed”. Do not treat signing as permission to apply treaty rates yet.
What this is
CDTAs help ensure residents are not taxed twice on the same income and let investors assess cross-border tax costs more clearly. Per the press release, Laos withholding on Hong Kong residents (highlights) includes:
- Dividends — from 10% to a minimum of 5% (subject to treaty text and conditions such as shareholding)
- Interest — from 10% to 5%
Actual rates depend on the treaty text, residence certificates and domestic law. On the Hong Kong side, tax paid in Laos under the CDTA may generally be credited against Hong Kong tax on the same income under Cap. 112, subject to Hong Kong tax law.
Before entry into force
- Signing ≠ entry into force — both sides must ratify; Hong Kong needs a CE in Council order and LegCo negative vetting.
- Do not apply treaty rates before entry into force — follow domestic law and already-in-force treaties until effective dates are published.
- Watch official pages — the IRD “CDTAs concluded” list and the Laos page will update order status and effective dates.
- Align with profits tax / offshore reviews — look at Hong Kong source rules and related disclosures, not only foreign withholding tax.
For the earlier six CDTA Orders gazetted in October 2026, see Six new CDTA Orders gazetted.
Sources: IRD press release (2026-10-29) · 稅務局新聞稿（中文） · CDTAs concluded · 已簽訂的全面性避免雙重課稅協定 · Laos page (Simplified Chinese)
Related services: Profits tax filing · Hong Kong company incorporation services · BVI & offshore company services · Hong Kong audit
Related: Six CDTA Orders gazetted (2026)