Treaty withHong Kong
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
| Payment | Treaty cap | Domestic rate without treaty | Conditions 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 sourcesArt. 10
|
| 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 sourcesArt. 11
|
| 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 sourcesArt. 12
|
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 sourcesApplies 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 pageUAE MLI position, OECD
Last checked 11 November 2026
UAE MLI position, OECDUAE 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 dashboardHong Kong Inland Revenue Department, synthesised text
Last checked 11 November 2026
Hong Kong Inland Revenue Department, synthesised textInland Revenue Ordinance (Cap. 112), sections 15(1)(b) and 21A and Schedule 8
Last checked 11 November 2026
Inland Revenue Ordinance (Cap. 112), sections 15(1)(b) and 21A and Schedule 8What 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.