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Three tests
The three tests
The reduced rate requires all of: (1) a Hong Kong certificate of resident status — applied for from the IRD (online or on form IR1313A), free of charge, typically issued within weeks for Mainland cases; (2) beneficial-owner status — examined by the Mainland under Guo Shui Han [2009] No. 601 and Announcement [2018] No. 9, with conduits and substance-less platforms denied; (3) the holding tests — the 5% dividend rate requires a direct holding of at least 25% for the required period. Missing one item, the full 10% applies.
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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.