LCQ20: Expanding Hong Kong's tax treaty network
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Question:
The Government signed the 57th Comprehensive Avoidance of Double Taxation Agreement (CDTA) with Barbados in March 2026 to expand Hong Kong's tax treaty network. There are views pointing out that in the context of an evolving global taxation environment, expanding the tax treaty network is crucial to consolidating Hong Kong's position as a leading destination for international business operations. In this connection, will the Government inform this Council:
(1) given that Singapore has signed over 90 CDTAs, a number far exceeds Hong Kong's current total of 57, whether the Government will formulate a more proactive timetable to catch up with the lag, so as to narrow the gap between Hong Kong and major economies of other regions in this regard;
(2) apart from increasing the number of CDTAs, whether the Government has assessed if the existing CDTAs (especially those which were signed at an earlier stage) still align with the prevailing international tax standard, and ensured that these CDTAs can continue to provide Hong Kong enterprises with competitive withholding tax rates and adequate legal protection;
(3) whether the Government will step up efforts in negotiating and concluding CDTAs with emerging markets along the Belt and Road, as well as with countries or regions with potential for collaborating with Hong Kong in innovation and technology, so as to facilitate bilateral trade flows and reduce tax costs for enterprises;
(4) of the resources and staffing establishment currently dedicated by the Government to expanding the tax treaty network; whether it will consider allocating additional resources in future to expedite the progress of negotiating and concluding CDTAs; and
(5) whether the Government has taken the initiative to publicise and promote to local chambers of commerce and investors in jurisdictions with which CDTAs have been signed, so as to assist multinational enterprises in fully understanding and making good use of CDTAs to optimise their global tax costs when considering the setting up of regional headquarters in Hong Kong, thereby attracting quality enterprises to Hong Kong and further developing the "headquarters economy"?
Reply:
President,
The Government has been proactively expanding the Comprehensive Avoidance of Double Taxation Agreement (CDTA) network, which will enable investors to better assess their potential tax liabilities from cross-border economic activities and avoid double taxation. This will foster a more attractive business environment, promoting bilateral trade and investment.
Having consulted the Commerce and Economic Development Bureau (CEDB), the Office for Attracting Strategic Enterprises (OASES) and the Inland Revenue Department (IRD), my reply to Dr the Hon Hoey Simon Lee's question is as follows:
(1), (3) and (5) Since the establishment of the Hong Kong Special Administrative Region Government, Hong Kong has started entering into CDTAs with major trading partners. Following the conclusion of an avoidance of double taxation arrangement with the Chinese Mainland in 1998, we signed a CDTA with Belgium in 2003, which was our first CDTA with an overseas jurisdiction. As of mid-April 2026, Hong Kong has signed CDTAs with 57 tax jurisdictions, 12 of which were signed by the current-term Government. We have also commenced negotiations with 17 tax jurisdictions. Depending on the content and complexity of the CDTAs, as well as the willingness and work priority of negotiation partners, we expect that three to four CDTAs will be signed this year.
According to the figures of 2025, 15 of Hong Kong's top 20 major trading partners have signed CDTAs with us. The trade value between Hong Kong and these 15 partners amounted to over 75 per cent of Hong Kong's total trade value. This shows that the current CDTA network suits Hong Kong's trade needs. To attract more enterprises to Hong Kong and facilitate enterprises to "go global" through Hong Kong, the Government will continue to proactively expand our CDTA network with a focus on jurisdictions participating in the Belt and Road (B&R) Initiative.
Apart from continuously expanding the CDTA network, the Government has been implementing various measures aiming to deepen the economic and trade co-operation with B&R countries and regions, and assist Hong Kong enterprises and professional services in exploring new business opportunities. the CEDB and the Belt and Road Office will continue to organise the annual flagship event - Belt and Road Summit; reach out to agencies in charge of projects in B&R countries and regions; organise missions, study tours and matching activities; as well as encourage and assist external organisations to stage roadshows in Hong Kong, with a view to promoting Hong Kong's diversified, professional and international professional services. Also, Invest Hong Kong has all along been assisting enterprises from all over the world to set up or expand businesses in Hong Kong, including economies along the B&R and with potential for collaboration in the field of innovation and technology. The department will continue to organise and sponsor an array of investment promotion activities, including roadshows, seminars and roundtables, to provide overseas enterprises with the latest information on Hong Kong's business environment, including leveraging the advantages of Hong Kong's CDTA network, thereby attracting more inward investment.
In addition, OASES is proactively engaging enterprises around the world with potential and that are technologically leading to establish a presence in Hong Kong. Apart from showcasing Hong Kong's overall strengths in terms of institutions, finance, professional services, and international connectivity, OASES will highlight Hong Kong's competitive tax policies and measures (including Hong Kong's CDTA network) to help enterprises more comprehensively assess the feasibility of establishing headquarters, research and development centres, and treasury management centres in Hong Kong. Among others, to further enhance Hong Kong's role as a key base for Corporate Treasury Centres (CTCs), the Government will provide additional tax incentives and flexibility to CTCs and their associated corporations, and at the same time strengthen promotion and communication with multinational enterprises, and enhance training for relevant practitioners, etc. The Government will announce an action plan in mid-2026, outlining the details of the aforementioned measures.
(2) The Government from time to time reviews and updates Hong Kong's CDTAs to ensure that they conform to the prevailing international tax standards and provide Hong Kong enterprises with competitive arrangements and sufficient safeguards.
In 2015, the Organisation for Economic Co-operation and Development (OECD) introduced the Base Erosion and Profit Shifting (BEPS) package with tax treaty-related measures, including prevention of treaty abuse and enhancement of the dispute resolution mechanism. The Government implemented the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Convention) of the package through local legislation in 2022 in order to modify CDTAs signed earlier for conforming to BEPS requirements. The CDTAs signed in recent years have also incorporated provisions that meet the standards of the Convention.
The prevailing withholding tax rates under Hong Kong's CDTAs are generally on par with those under the CDTAs of our major trading partners in the region and some of ours are even more favourable. Besides, our CDTAs clearly set out the taxing rights of the governments of the two sides, residents and taxes covered, arrangements for elimination of double taxation, withholding tax rates, dispute resolution mechanism, information exchange arrangements between the tax authorities, etc, so as to provide enterprises with tax certainty and legal protection.
(4) The Financial Services and the Treasury Bureau and the IRD are responsible for duties in relation to expansion of the CDTA network. The major officers involve one Principal Assistant Secretary for Financial Services and the Treasury, one Assistant Commissioner of Inland Revenue (directorate officer at D2 level) and seven officers from the grades of administrative officer, assessor and executive officer. To cope with the increasing workload related to CDTAs and other international tax matters, the IRD created the aforementioned post of Assistant Commissioner in June 2023 to strengthen support at the directorate level. To meet operational needs, we will arrange internal deployment or increase manpower as appropriate.
Ends/Wednesday, April 22, 2026
Issued at HKT 12:30
Issued at HKT 12:30
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