China – Hong Kong Tax Treaty
The China-Hong Kong tax treaty caps withholding on dividends at 10% for portfolio investors and 5% for qualifying direct investment, and interest at 7%. Royalties are taxed at a uniform 7% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 47 active treaties in China's network and one of 23 in Hong Kong's. The general dividend rate of 10% compares to a median of 10% across China's network and 10% across Hong Kong's.
Verified data
SAT International Tax Treaties (chinatax.gov.cn) (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)
Withholding Rate Summary
Source: China Treaty Reference| Income Type | Treaty Rate | Statutory Rate (China) |
|---|---|---|
| Dividends (general) Portfolio investors | 10% | 10% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 5% | 10% |
| Interest Bank interest, bonds, loans | 7%saves 3% | 10% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 7% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (China)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 10% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 10%.
Source: China Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 7% withholding under this treaty, compared to the 10% statutory rate. This represents a 3% reduction from the statutory rate.
Source: China Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 7% to 7%.
Source: China Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: China Treaty Reference
Comparative Context
🇨🇳China's Network
Among China's 47 active treaty partners, the 10% general dividend rate ranks 16th (median: 10%).
| Partner | Rate |
|---|---|
| France | 10% |
| United Kingdom | 10% |
| Greece | 10% |
| Hong Kong (this treaty) | 10% |
| Hungary | 10% |
| Indonesia | 10% |
| Ireland | 10% |
🇭🇰Hong Kong's Network
Among Hong Kong's 23 active treaty partners, the 10% general dividend rate ranks 4th (median: 10%).
| Partner | Rate |
|---|---|
| United States | 0% |
| United Arab Emirates | 5% |
| Switzerland | 10% |
| China (this treaty) | 10% |
| Germany | 10% |
| Finland | 10% |
| France | 10% |