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The UAE and Hong Kong tax treaty.

What the treaty means if you or your company has income, profits or residence in both countries.

Position as at 11 November 2026

Applies from: Art 27(2): Hong Kong, years of assessment from 1 Apr 2016 (2016/17); UAE, from 1 Jan 2016

Entry into force: 10 December 2015

Signed: 11 December 2014

Withholding rates

What tax is taken at source.

Last checked 11 November 2026. Sources

What tax is taken at source.
PaymentTreaty capDomestic rate without treatyConditions and evidence
DividendsArt. 10 5% Hong Kong rate without the treaty: 0% (no withholding tax on dividends)

Treaty cap 5% (0% for UAE government bodies). Hong Kong itself charges no withholding tax on dividends.

1 of 2 official sources

Art. 10

  • IRDLast checked 11 November 2026.
InterestArt. 11 5% Hong Kong rate without the treaty: 0% (no withholding tax on interest)

Treaty cap 5%. Hong Kong itself charges no withholding tax on interest.

1 of 2 official sources

Art. 11

  • IRDLast checked 11 November 2026.
RoyaltiesArt. 12 5% Hong Kong rate without the treaty: up to 4.95% for a company (Hong Kong taxes 30% of the royalty at its 16.5% profits tax rate). 16.5% of the full royalty if it's paid to an associate and the rights were once owned by a Hong Kong business.

Capped at 5%, including payments for using equipment.

1 of 2 official sources

Art. 12

  • IRDLast checked 11 November 2026.

Where the treaty rate is lower, it usually applies only once you claim it with a UAE tax residence certificate. The UAE charges 0% on these payments. Hong Kong already charges no withholding tax on dividends or interest, so the treaty cap does not reduce those rates.

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Sources for the Hong Kong treaty

6 of 6 official sources

Applies from: Art 27(2): Hong Kong, years of assessment from 1 Apr 2016 (2016/17); UAE, from 1 Jan 2016

Entry into force: 10 December 2015

Agreement between the Government of the Hong Kong Special Administrative Region of the People's Republic of China and the Government of the United Arab Emirates for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

IRD treaty page

Last checked 11 November 2026

IRD treaty page
UAE MLI position, OECD

Last checked 11 November 2026

UAE MLI position, OECD
UAE Ministry of Finance, treaty table (2023)

Last checked 11 November 2026

UAE Ministry of Finance, treaty table (2023)
UAE Ministry of Finance, treaty dashboard

Last checked 11 November 2026

UAE Ministry of Finance, treaty dashboard
Hong Kong Inland Revenue Department, synthesised text
Inland Revenue Ordinance (Cap. 112), sections 15(1)(b) and 21A and Schedule 8

What changed on this page

No checked change events are available in this dataset.

Position as at 11 November 2026. How we check

Moving from Hong Kong

Where you are resident for tax.

UAE individual: "ordinarily resides in the United Arab Emirates"; UAE company: incorporated in the UAE or, if incorporated elsewhere, "normally managed or controlled" there (Art 4(1)(b)).

Running a company

When a Hong Kong business is taxed in the UAE.

Place of effective management (Art 4(3)).

Selling assets

Selling shares or property.

May be taxed where the property is (Art 13(1)). Shares deriving more than 50% of asset value directly or indirectly from immovable property may be taxed in the situs party. Excludes shares quoted on a stock exchange agreed by the parties, shares transferred in a reorganisation, merger or similar operation, and shares in a company whose immovable property is used in carrying on its business (Art 13(4)(a)-(c)).

Pensions

Pensions and retirement income.

Private pensions: residence party only, including lump sums (Art 17(1)); public social security and recognised retirement schemes taxed only in the scheme party (Art 17(2)). Government-service pensions: taxable only in the paying party, unless the individual is resident in the other party and the case falls within Art 18(1)(b) (Art 18(2)).

Treaty updates

How the multilateral instrument changes this treaty.

Covered tax agreement for both (HK item 37, UAE item 43). MLI in force China incl. HKSAR 1 Sep 2022; UAE 1 Sep 2019. Effect in HK: WHT 1 Apr 2023, other taxes YA from 1 Apr 2024; in UAE: WHT 1 Jan 2024, other taxes periods from 23 Sep 2023. Applied: preamble, PPT, MAP.

Checked by PBF against official sources. Position as at 11 November 2026. How we check

PBF UAE Tax Hub. General information, not advice.

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