Hong Kong – United States Tax Treaty
The Hong Kong-United States tax treaty caps withholding on dividends at 0%, with interest payments fully exempt at 0%. Royalties are taxed at a uniform 5% across all categories. 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 64 in United States's. The general dividend rate of 0% is below the median in both countries' treaty networks (Hong Kong: 10%, United States: 15%).
Verified data
Inland Revenue Department Hong Kong (ird.gov.hk) - Comprehensive Double Taxation Agreements (Treaty list verified April 2026. Rates from individual CDTA texts (Articles 10-12). Hong Kong has 0% WHT on dividends and interest. Royalty WHT is effectively 4.95% (16.5% profits tax on 30% deemed profit for non-resident), rounded to 5% statutory rate.)
Withholding Rate Summary
Source: Hong Kong Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Hong Kong) |
|---|---|---|
| Dividends (general) Portfolio investors | 0% | 0% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 0% | 0% |
| Interest Bank interest, bonds, loans | 0% | 0% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 5% | — |
| 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 (Hong Kong)” 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 0% applies to portfolio investors. A reduced rate of 0% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 0%.
Source: Hong Kong Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 0% withholding under this treaty, compared to the 0% statutory rate. Interest is fully exempt from source-country withholding under this treaty.
Source: Hong Kong Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 5% to 5%.
Source: Hong Kong 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: Hong Kong Treaty Reference
Comparative Context
🇭🇰Hong Kong's Network
Among Hong Kong's 23 active treaty partners, the 0% general dividend rate ranks 1st (median: 10%).
| Partner | Rate |
|---|---|
| United States (this treaty) | 0% |
| United Arab Emirates | 5% |
| Switzerland | 10% |
| China | 10% |
🇺🇸United States's Network
Among United States's 64 active treaty partners, the 0% general dividend rate ranks 3rd (median: 15%).
| Partner | Rate |
|---|---|
| United Arab Emirates | 0% |
| Brazil | 0% |
| Hong Kong (this treaty) | 0% |
| Malaysia | 0% |
| Saudi Arabia | 5% |
| Bulgaria | 10% |