Signing of tax pact with Slovenia marks new Hong Kong milestone in expanding international tax co-operation with 60th tax pact signed (with photos)

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     The Secretary for Financial Services and the Treasury, Mr Christopher Hui, had a bilateral meeting with the Ambassador of the Republic of Slovenia to China, Mr Boštjan Malovrh, in Hong Kong today (September 4) and signed on behalf of the Hong Kong Special Administrative Region (HKSAR) Government a comprehensive avoidance of double taxation agreement (CDTA) with the Government of Slovenia.

     Mr Hui said, "This is the 60th CDTA that Hong Kong has concluded, the 15th one that the current-term Government has signed, and the fifth one this year. It marks a new milestone of the HKSAR Government's efforts in proactively expanding Hong Kong's CDTA network.

     "Slovenia is an important trading partner of Hong Kong in Europe and a participant in the Belt and Road Initiative. Last September, I travelled to Slovenia to discuss the early conclusion of the CDTA between our two jurisdictions and received a positive response from the Slovenian Government, which has led to the formal signing of the agreement by both sides today. The CDTA sets out the allocation of taxing rights between Hong Kong and Slovenia, which will enable investors to better assess their potential tax liabilities from cross-border economic activities and avoid double taxation, thereby promoting bilateral trade and investment.

     "The Financial Services and the Treasury Bureau is also actively following up on the consensus to strengthen co-operation reached during the Chief Executive's visit to two Central Asian countries this June. We have completed CDTA negotiations with Kazakhstan and the CDTA will be signed once both sides have completed the internal procedures. We will also commence negotiations with Uzbekistan later this year."

     At the bilateral meeting, Mr Hui highlighted to Mr Malovrh the latest developments of Hong Kong as an international financial centre, including its top-tier global positions in areas such as cross-boundary wealth management, global competitiveness and tax policy, as well as the HKSAR Government's initiatives to develop Hong Kong into a global gold trading, clearing and reserve hub.

     In accordance with this CDTA, any tax paid by Hong Kong residents in Slovenia will be allowed as a credit against the tax payable in Hong Kong in respect of the same income, subject to the provisions of the Inland Revenue Ordinance (Cap. 112) (IRO). Moreover, Slovenia's withholding tax rate for Hong Kong residents on dividends, currently at up to 25 per cent, will be reduced to 10 per cent at maximum, while the withholding tax rates on interest and royalties, currently at up to 25 per cent, will also be reduced to 5 per cent.

     The CDTA will come into force after completion of ratification procedures by both sides. In Hong Kong, the Chief Executive in Council will make an order under the IRO in respect of the CDTA, which will be tabled at the Legislative Council for negative vetting. Details are available on the Inland Revenue Department's website.

Ends/Friday, September 4, 2026
Issued at HKT 17:24

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The Secretary for Financial Services and the Treasury, Mr Christopher Hui (right), and the Ambassador of the Republic of Slovenia to China, Mr Boštjan Malovrh (left), sign on behalf of the Hong Kong Special Administrative Region Government and the Government of Slovenia respectively a comprehensive avoidance of double taxation agreement today (September 4).

The Secretary for Financial Services and the Treasury, Mr Christopher Hui (right), exchanges documents with the Ambassador of the Republic of Slovenia to China, Mr Boštjan Malovrh (left), after signing a comprehensive avoidance of double taxation agreement today (September 4).

The Secretary for Financial Services and the Treasury, Mr Christopher Hui, and the Ambassador of the Republic of Slovenia to China, Mr Boštjan Malovrh, signed on behalf of the Hong Kong Special Administrative Region (HKSAR) Government and the Government of Slovenia respectively a comprehensive avoidance of double taxation agreement today (September 4). Photo shows (from left) the Honorary Consul of the Republic of Slovenia in the HKSAR and the Macao SAR, Mr Lau Wing-kong, Michael; Mr Malovrh; Mr Hui; the Commissioner of Inland Revenue, Mr Benjamin Chan; and the Deputy Secretary for Financial Services and the Treasury (Treasury), Mr Anson Lai, at the signing ceremony.