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Reduced rates
Content date: 2026-08-24
The usual rates
Dividends, interest and royalties are the three most-used items in Mainland-to-Hong Kong payments (see table). The Arrangement is not automatic — withholding is first applied at the 10% domestic rate, with the Arrangement rate obtained through filing or refund where the conditions are met.
Rate comparison for the common items
| Item | Arrangement rate | Domestic rate | Main conditions |
|---|---|---|---|
| Dividends | 5% | 10% | Beneficial owner with a direct holding of at least 25% |
| Dividends (other cases) | 10% | 10% | — |
| Interest | 7% | 10% | Certificate of resident status + beneficial owner |
| Royalties | 7% | 10% | Certificate of resident status + beneficial owner |
| Business profits | Not taxable | — | No permanent establishment in the Mainland |
Case-specific decisions differ — book a consultation with our advisers.
The content of this page is general professional information and does not constitute tax, legal or investment advice. For specific cases, please consult a Hong Kong practising accountant or tax adviser, or refer to official publications of the IRD / SFC / HKMA / CR.