Orbitax subscribers can now easily follow the latest COVID-19-related tax measures being implemented worldwide. New to Orbitax? Create a free account to access your dashboard and latest tax news.
News Share

The Tax Hub

Daily Tax Newsletter

Hong Kong; Qatar

Responsive image

Treaty between Hong Kong and Qatar – details

Details of the Hong Kong - Qatar Income Tax Agreement (2013), signed on 13 May 2013, have become available. The treaty was concluded in the Chinese, Arabic and English languages, all texts having equal authenticity. In the case of divergence, however, the English text will prevail. The treaty generally follows the UN Model (2001).

The maximum rates of withholding tax are:

-   0% on dividends;
-   0% on interest; and
-   5% on royalties.

Deviations from the UN Model (2001) include that:

-   the term permanent establishment (PE) defined under article 5(2) includes within its ambit any premises used as sales outlet or a farm or plantation;
-   article 7(1) does not include a provision on the force of attraction;
-   article 7(3) does not impose any restriction as regards deduction in respect of payments made by way of royalties, fees or other similar payments made to the head office, but leaves the calculation of the profits according to the domestic laws of the contracting state in which the PE is situated;
-   paragraph 1 of the protocol provides with regard to article 9(2) that adjustments made in respect of transactions between associated enterprises of a contracting party will be accepted by the other contracting party only if the adjustment made by the first-mentioned contracting party is justified both in principle and as regards the amount;
-   no relief under articles 10, 11 or 12 would be available if the main purpose of any person concerned with the creation or assignment of the rights in respect of which the payments are made is only to take advantage through such creation or assignment;
-   article 13 (Capital Gains) follows the OECD Model (2010);
-   article 13(4), which allocates taxing rights in respect of capital gains derived from alienation of shares in a company which derives 50% or more of its value directly or indirectly from immovable property to the contracting state in which the immovable property is situated, includes certain exceptions covering capital gains on the alienation of shares:
(a)   quoted on a stock exchange;
(b)   exchanged in the framework of a reorganization of a company, a merger, a scission or a similar operation; or
(c)   in a company deriving more than 50 per cent of its asset value from immovable property in which it carries on its business;
-   article 21 (Other Income) follows the OECD Model (2010);
-   paragraph 3 of the protocol provides that non-taxation of Qatari nationals would not be regarded as a discrimination under the provisions of article 23 (Non-Discrimination);
-   article 24 (Mutual Agreement Procedure) does not contain an arbitration provision to resolve disputes between the contracting states; and
-   the treaty does not contain an article in respect of assistance in the collection of taxes.

Both states provide for the credit method to avoid double taxation.

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

FX Rates

Global FX Rates including Tax year Average FX Rates and Spot Rates for all Reporting Currencies.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More