Hong Kong Withholding tax rates

What this value means

THERE IS NO SINGLE WITHHOLDING TAX RATE, WHICH IS WHY value IS NULL. Hong Kong levies no withholding tax whatsoever on dividends or interest paid to non-residents (both served as explicit zero-rate entries, not omitted), while royalties for intellectual property carry a deemed-profits charge whose effective rate depends on both the recipient's relationship to the payer and the payer's history with the IP (4.95% in the normal case, 16.5% in the anti-avoidance case, for corporate recipients). A caller wanting a number must name which payment type; read withholding_rates rather than expecting a headline figure. ALL RATES ARE DOMESTIC STATUTORY RATES, BEFORE TREATY RELIEF. Hong Kong's comprehensive double taxation agreements can cap the royalty charge below the domestic effective rate, and relief depends on the recipient's residence and beneficial ownership. We do NOT serve treaty rates: they are bilateral and applying one is a legal determination rather than a lookup. DIPN 22 itself discusses when the DTA royalties article displaces the domestic charge. MECHANICS OF THE ROYALTY CHARGE: IRO s. 15(1)(b) deems sums received by a non-resident 'for the use, or the right to the use, in Hong Kong of any patent, design, trade mark, copyright material, layout-design (topography) of an integrated circuit, performer's right, plant variety right, secret process or formula' to be trading receipts chargeable to profits tax; s. 15(1)(ba) (added 2004) extends this to use OUTSIDE Hong Kong where the sums are deductible against the payer's Hong Kong profits. Under s. 21A, per DIPN 22 para. 27: 'the assessable profits in respect of a sum specified in section 15(1)(a), (b) or (ba) are deemed to be 30% of the sum received or accrued except where the intellectual property was previously "owned" by a person carrying on a trade, profession or business in Hong Kong and the sum is paid or accrues to an "associate". In the latter case, 100% of the sum paid or accrued is taken as the assessable profits.' The deemed profits are then taxed at the profits tax rate — 16.5% for corporations (15% unincorporated) — giving effective rates on the gross royalty of 30% x 16.5% = 4.95% normally, or 100% x 16.5% = 16.5% in the associate/previously-HK-owned case. The tax is collected from the Hong Kong payer, who must withhold sufficient funds (IRO ss. 20B). The 100% deeming is an anti-avoidance rule against 'sale and license back' schemes (DIPN 22 para. 28). The series effective_from is 1 April 2018 (year of assessment 2018/19), when the two-tiered profits tax rates took effect — the most recent change bearing on any effective rate here; the 16.5% normal corporate rate itself dates from 2008/09. Two-tiered nuance: a non-resident's first HK$2,000,000 of assessable (deemed) profits can qualify for 8.25% (corporations), making the effective royalty rate as low as 2.475% on that slice, subject to the one-entity-per-group election. SCOPE NOTE ON SERVICE FEES: Hong Kong levies no withholding on pure service fees paid to non-residents; a non-resident's service income is taxable only if it carries on business in Hong Kong with Hong Kong-sourced profits (territorial principle: 'Only profits/income arising in or derived from Hong Kong is chargeable to tax' — FSTB). No general service-fee entry is therefore served.

Get it programmatically

curl https://asiaref.dev/v1/hk/withholding-tax
# $0.005 per call — x402 on Base (USDC). No key, no signup.
# History:    curl https://asiaref.dev/v1/hk/withholding-tax/history?from=2020-01-01
# Provenance: curl https://asiaref.dev/provenance/hk/withholding-tax

Other Hong Kong series: HKMA Base Rate · Value-added tax / GST · VAT registration threshold · Statutory Minimum Wage (SMW) · General holidays · Composite CPI inflation (year-on-year) · Profits Tax rate (corporations) · Statutory late-payment interest · Salaries Tax (progressive rates) · Statutory social-insurance contributions

The same figure elsewhere: India · Indonesia · Iraq · Israel · Japan · all 28