On 6 October 2026, the Chief Executive in Council made six Orders under the Inland Revenue Ordinance (Cap. 112) to implement Comprehensive Avoidance of Double Taxation Agreements (CDTAs) that Hong Kong signed with Barbados, Jordan, the Kyrgyz Republic, Maldives, Norway and Rwanda. The Orders were gazetted on 16 October and tabled at the Legislative Council on 21 October for negative vetting. This note summarises the official press release and annex for Hong Kong businesses with cross-border income — general information only, not tax advice.
The six CDTAs enter into force only after both Hong Kong and the other jurisdiction complete their ratification procedures. Gazettal / LegCo tabling is not the same as entry into force; confirm effective dates against official publications.
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 official release, Hong Kong has signed CDTAs with 60 jurisdictions, 15 of them under the current-term Government. These six agreements were signed between May 2025 and March 2026.
Annex highlights: withholding tax caps (other side on Hong Kong residents)
Summary of the official annex (actual rates depend on the treaty text, residence certificates and domestic law):
- Barbados — dividends exempt; interest and royalties capped at 5% (if charged in future); international traffic profits not taxed in Barbados
- Jordan — dividends, interest and royalties cut from up to 10% to a 5% cap; international shipping profits not taxed in Jordan
- Kyrgyz Republic — dividends capped at 5% or 10% (by shareholding); interest and royalties cut from up to 10% to an 8% cap; international traffic profits not taxed locally
- Maldives — dividends capped at 5% or 10% (by shareholding); international shipping profits get a 50% reduction; international air transport profits not taxed in Maldives
- Norway — dividends cut from up to 25% to a 15% cap; interest and royalties capped at 5% (if charged in future)
- Rwanda — dividends, interest and royalties cut from up to 15% to caps of 7.5%, 8% and 9% respectively; international traffic profits not taxed in Rwanda
Each agreement also sets employment-income exemptions (including, among other conditions, an aggregate stay of not more than 183 days in any relevant 12-month period). On the Hong Kong side, tax paid in the other jurisdiction under the CDTA is generally allowed as a credit against Hong Kong tax on the same income, subject to Hong Kong tax law.
Practical tips for SMEs / company secretaries / cross-border groups
- Map counterparties in these six places — review dividends, interest, royalties, services or shipping/air income before treating treaty rates as available.
- Do not apply treaty rates before entry into force — until ratification and effective dates are published, follow domestic law and already-in-force treaties.
- Prepare residence certificates early — treaty relief usually needs Hong Kong tax residence proof and the other side’s forms; diary the document pack with your tax advisor.
- Align with profits tax / offshore income reviews — look at Hong Kong source rules, FSIE and transfer-pricing disclosures, not only foreign withholding tax.
- Watch LegCo negative vetting and IRD updates — use the IRD “CDTAs concluded” page as the source of truth.
Sources: IRD press release (2026-10-14) · 稅務局新聞稿（中文） · Annex PDF (six CDTA highlights) · CDTAs concluded · 已簽訂的全面性避免雙重課稅協定
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