UAE and Hong Kong · Royalties
Position as at 11 November 2026
Withholding rates
What tax is taken at source.
Last checked 11 November 2026.
Hong Kong → UAE
| Payment | Treaty cap | Domestic rate without treaty | Conditions and evidence |
|---|---|---|---|
| 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. Hong Kong already charges no withholding tax on dividends or interest, so the treaty cap does not reduce those rates.
UAE → Hong Kong
The UAE charges 0% on these payments.
Checked by PBF against official sources. Position as at 11 November 2026. How we check
PBF UAE Tax Hub. General information, not advice.