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Ireland; Hong Kong

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Treaty between Ireland and Hong Kong – details

Details of the income tax treaty and protocol between Ireland and Hong Kong, signed on 22 June 2010, have become available. The treaty was concluded in English language and generally follows the OECD Model Convention.

The taxes covered by the treaty are:

in the case of Hong Kong:

-   profits tax;
-   salaries tax;
-   property tax; and

in the case of Ireland:

-   income tax;
-   income levy;
-   corporation tax; and
-   capital gains tax.

Withholding tax

The treaty applies maximum rates of withholding tax for any dividends, interest and royalty payments made by a company which is resident of a contracting party to a resident of the other contracting party.

The maximum rates of withholding are:

-   0% for dividends;
-   10% for interest, or 0% in certain circumstances; and
-   3% for (gross) royalties.

It is required that the income recipient is both a "resident" of the other contracting state, and is the beneficial owner of the income in question.

Residence

A resident of Hong Kong is defined specifically for the purposes of the treaty to mean:

-   an individual who ordinarily resides in Hong Kong;
-   an individual who stays in Hong Kong for more than 180 days during the year or for more than 300 days in 2 consecutive years;
-   a company incorporated in Hong Kong, or, if incorporated outside Hong Kong, being centrally managed and controlled there; or
-   any other person constituted under the laws of Hong Kong, or if constituted outside Hong Kong, being centrally managed and controlled there.

A resident of Ireland is defined to mean any person who, under the laws of Ireland is liable to tax therein by reason of domicile, residence, place of management or similar criterion. It does not include a person who is liable to tax in Ireland in respect only of income sources in Ireland.

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