Hong Kong – Thailand Tax Treaty
The Hong Kong-Thailand tax treaty caps withholding on dividends at 10%, and interest at 10%. Royalty rates vary by category, from 10% on copyright to 15% on film and television. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 23 active treaties in Hong Kong's network and one of 22 in Thailand's. The general dividend rate of 10% compares to a median of 10% across Hong Kong's network and 15% across Thailand's.
Verified data
Revenue Department of Thailand (rd.go.th) - Double Taxation Agreements (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12). Thailand WHT: dividends 10%, interest 15%, royalties 15%.)
Withholding Rate Summary
Source: Thailand Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Thailand) |
|---|---|---|
| Dividends (general) Portfolio investors | 10% | 10% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 10% | 10% |
| Interest Bank interest, bonds, loans | 10%saves 5% | 15% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 11.3% | — |
| 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 (Thailand)” 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 10% 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: Thailand Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 10% withholding under this treaty, compared to the 15% statutory rate. This represents a 5% reduction from the statutory rate.
Source: Thailand Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 10% to 15%.
Source: Thailand 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: Thailand Treaty Reference
Comparative Context
🇭🇰Hong Kong's Network
Among Hong Kong's 23 active treaty partners, the 10% general dividend rate ranks 17th (median: 10%).
| Partner | Rate |
|---|---|
| Malaysia | 10% |
| Netherlands | 10% |
| Singapore | 10% |
| Thailand (this treaty) | 10% |
| Vietnam | 10% |
| Australia | 15% |
| Canada | 15% |
🇹🇭Thailand's Network
Among Thailand's 22 active treaty partners, the 10% general dividend rate ranks 3rd (median: 15%).
| Partner | Rate |
|---|---|
| United Arab Emirates | 10% |
| United Kingdom | 10% |
| Hong Kong (this treaty) | 10% |
| South Korea | 10% |
| Malaysia | 10% |
| Singapore | 10% |