2011-11-14-KPMG_China-香港与马耳他共和国签订避免双重征税协定_3页_114kb

Summary of Hong Kong-Tax Alerts Issue 20 - November 2011

Hong Kong-Malta Double Taxation Agreement

• Signed on November 8, 2011, marking Hong Kong's 22nd comprehensive agreement.
• Allocates taxing rights between the two jurisdictions, providing clarity on tax liabilities for cross-border economic activities.
• Specified withholding tax rates:
  • Dividends: 15% treaty rate, 0% non-treaty rate.
  • Interest: 15% treaty rate, 0% non-treaty rate.
  • Royalties: 15% treaty rate, 3% non-treaty rate.
• Offers tax credit in Malta for Hong Kong Profits Tax paid on Maltese company profits.
• Effective dates: Hong Kong from year of assessment beginning April 1, 2012; Malta from January 1, 2012.

Hong Kong-New Zealand Double Taxation Agreement

• Entered into force on November 9, 2011.
• Hong Kong effective from year of assessment beginning April 1, 2012.
• New Zealand effective for withholding tax from April 1, 2012 and for other taxes similarly.
• Reinforces Malta's role as an investment jurisdiction for foreign direct investment.