Hong Kong · Enacted legislation
Hong Kong gazettes six tax-treaty Orders
On 16 October 2026, Hong Kong gazetted six Orders implementing comprehensive double-taxation agreements with Barbados, Jordan, the Kyrgyz Republic, Maldives, Norway and Rwanda. The instruments do not yet make treaty relief available: each agreement must first complete its entry-into-force procedures.
- Official document:
- Inland Revenue (Double Taxation Relief and Prevention of Fiscal Evasion) Orders, Legal Notices 115–120 of 2026
- Development date:
- 2026-10-16
Six implementation instruments
The Chief Executive in Council made the Orders on 6 October under section 49 of the Inland Revenue Ordinance. Legal Notices 115–120 of 2026 implement the six agreements in Hong Kong law. The agreements allocate taxing rights, provide double-tax relief and establish source-country limits for specified cross-border income. The Inland Revenue Department says each treaty enters into force only after both parties complete their domestic procedures and notify one another, so the Orders are enacted but the treaty benefits are not yet claimable.[1][2]
Barbados, Jordan and the Kyrgyz Republic
The Barbados agreement exempts source-country dividends, caps interest at 5%, and caps royalties at 3% for qualifying intellectual property or 5% otherwise. Jordan sets 5% limits for dividends, interest and royalties. Under the Kyrgyz Republic agreement, dividends are capped at 5% where the beneficial owner is a company holding at least 20% directly throughout a 365-day period, and at 10% otherwise; interest and royalties are capped at 8%. Each agreement also contains foreign-tax-credit, permanent-establishment, associated-enterprise and anti-abuse provisions.[3][4][5]
Maldives, Norway and Rwanda
Maldives applies 5% and 10% dividend limits using a 25% direct-holding threshold and a 365-day holding period. It caps interest, royalties and technical-service fees at 10%, while source-country tax on international shipping profits is reduced by 50%. Norway applies a 5% dividend rate to a company holding at least 10% directly for 365 days and a 15% rate otherwise; its permanent-establishment article includes a six-month construction threshold and a services test exceeding 183 days in a 12-month period. Rwanda caps dividends at 7.5%, interest at 8%, royalties at 9% and technical-service fees at 10%.[6][7][8]
Relief is not yet available
Hong Kong application generally begins with the year of assessment starting on or after 1 April in the calendar year following entry into force; the partner-country commencement rule must be checked in the relevant treaty. Groups should therefore model the prospective rates separately and confirm residence, beneficial ownership, holding periods, permanent-establishment exposure and principal-purpose or other anti-abuse conditions before changing payment or ownership structures. The 14 October announcement said the Orders were intended to be tabled before the Legislative Council on 21 October; it did not itself establish that tabling later occurred.[1][3][4][5][6][7][8]
Official sources
- [1] Hong Kong signs Comprehensive Avoidance of Double Taxation Agreements with six jurisdictions
Inland Revenue Department, Hong Kong · Document date: 2026-10-14
Complete official release read; Orders made by the Chief Executive in Council on 6 October 2026 under section 49 of the Inland Revenue Ordinance, gazettal scheduled for 16 October, intended Legislative Council tabling on 21 October, and entry into force only after both parties complete domestic procedures. The gazettal date was reconciled against the six official Order records.
- [2] Annex: Comprehensive Avoidance of Double Taxation Agreements with six jurisdictions
Inland Revenue Department, Hong Kong · Document date: 2026-10-14
Pages 1–4 read; partner jurisdictions, treaty scope, rate comparisons and implementation procedure for the six Orders.
- [3] Agreement between Hong Kong and Barbados for the Elimination of Double Taxation
Government of the Hong Kong Special Administrative Region and Government of Barbados · Document date: 2026-05-30
Articles 5, 9–12, 22, 26 and 28 read; permanent establishment, associated enterprises, dividends, interest, royalties, elimination of double taxation, principal-purpose test and entry into force.
- [4] Agreement between Hong Kong and Jordan for the Elimination of Double Taxation
Government of the Hong Kong Special Administrative Region and Government of the Hashemite Kingdom of Jordan · Document date: 2026-02-18
Articles 5, 9–12, 22, 26 and 28 read; permanent establishment, associated enterprises, dividends, interest, royalties, elimination of double taxation, principal-purpose test and entry into force.
- [5] Agreement between Hong Kong and the Kyrgyz Republic for the Elimination of Double Taxation
Government of the Hong Kong Special Administrative Region and Cabinet of Ministers of the Kyrgyz Republic · Document date: 2026-02-19
Articles 5, 9–12, 22, 26 and 28 read; permanent establishment, associated enterprises, dividends including the 365-day holding condition, interest, royalties, double-tax relief, principal-purpose test and entry into force.
- [6] Agreement between Hong Kong and Maldives for the Elimination of Double Taxation
Government of the Hong Kong Special Administrative Region and Government of the Republic of Maldives · Document date: 2025-10-29
Articles 5, 8, 10–13, 23, 27 and 29 read; permanent establishment, shipping, dividends, interest, royalties, technical-service fees, double-tax relief, principal-purpose test and entry into force.
- [7] Agreement between Hong Kong and Norway for the Elimination of Double Taxation
Government of the Hong Kong Special Administrative Region and Government of the Kingdom of Norway · Document date: 2025-10-22
Articles 5, 9–12, 23, 27 and 29 read; construction and service permanent-establishment tests, associated enterprises, dividends including the 365-day condition, interest, royalties, double-tax relief, principal-purpose test and entry into force.
- [8] Agreement between Hong Kong and Rwanda for the Elimination of Double Taxation
Government of the Hong Kong Special Administrative Region and Government of the Republic of Rwanda · Document date: 2025-05-30
Articles 5, 9–13, 23, 27 and 29 read; permanent establishment, associated enterprises, dividends, interest, royalties, technical-service fees, double-tax relief, principal-purpose test and entry into force.