What is the dividend withholding rate between China and Hong Kong?

Under the China-Hong Kong tax treaty, the withholding rate on dividends is 10% for portfolio investors (general rate). A reduced rate of 5% applies when the beneficial owner is a company holding a qualifying ownership stake (typically 10% or more of voting stock). Note that the reduced rate requires the recipient to file the appropriate treaty benefit claim form before payment. This 10% rate compares to a median of 10% across China's 47 active treaty partners, and 10% across Hong Kong's 23 active partners.