Switzerland – Hong Kong Tax Treaty
The Switzerland-Hong Kong tax treaty caps withholding on dividends at 10% for portfolio investors and 0% for qualifying direct investment, with interest payments fully exempt at 0%. Royalties are taxed at a uniform 3% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 49 active treaties in Switzerland's network and one of 23 in Hong Kong's. The general dividend rate of 10% compares to a median of 15% across Switzerland's network and 10% across Hong Kong's.
Verified data
Swiss Federal Tax Administration (estv.admin.ch) - Double Taxation Agreements overview and treaty texts (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)
Withholding Rate Summary
Source: Switzerland Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Switzerland) |
|---|---|---|
| Dividends (general) Portfolio investors | 10%saves 25% | 35% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 0%saves 35% | 35% |
| Interest Bank interest, bonds, loans | 0% | 0% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 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 (Switzerland)” 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 0% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 35%.
Source: Switzerland 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: Switzerland Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 3% to 3%.
Source: Switzerland 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: Switzerland Treaty Reference
Comparative Context
🇨🇭Switzerland's Network
Among Switzerland's 49 active treaty partners, the 10% general dividend rate ranks 5th (median: 15%).
| Partner | Rate |
|---|---|
| Saudi Arabia | 5% |
| China | 10% |
| Finland | 10% |
| Hong Kong (this treaty) | 10% |
| Hungary | 10% |
| India | 10% |
| Japan | 10% |
🇭🇰Hong Kong's Network
Among Hong Kong's 23 active treaty partners, the 10% general dividend rate ranks 3rd (median: 10%).
| Partner | Rate |
|---|---|
| United States | 0% |
| United Arab Emirates | 5% |
| Switzerland (this treaty) | 10% |
| China | 10% |
| Germany | 10% |
| Finland | 10% |