The agreement applies in the United Kingdom from 1 April 2011 for corporation tax and from 6 April 2011 for income and capital gains tax. It applies from April 1, 2011 in Hong Kong. "The conclusion of a comprehensive double taxation agreement with the continent, as well as the closer economic partnership agreement on the mainland and in Hong Kong, will further encourage international investors to enter the continental market via Hong Kong. In addition, cross-border financing agreements and the transfer of technical know-how and patents between the two sites will be improved. These will help stimulate Hong Kong`s economy, strengthen our competitiveness and attract foreign capital. In September 2012, the Commissioner for Finance stated that Hong Kong had made "remarkable progress" in establishing its international network of tax treaties since the change in the internal income system in March 2010, and that since then the network of tax treaties in Hong Kong has rapidly expanded. As of March 2018, 37 global double taxation agreements were in force in Hong Kong. Implementation of a tax agreement between France and Hong Kong could also limit the scope of FTC Article 209B or 990E of the same code. This tax treaty could also eliminate the risk of the FTC`s section 123 bis (this section is applied to individuals).
These articles complement French anti-avoidance schemes by submitting the profits of branches and subsidiaries in which a French company holds more than 50% of the corporate tax in France (only if these companies are established in a low-tax country and do not provide evidence of industrial or commercial activities on the ground). Nevertheless, with its recent reforms and willingness to enter into tax agreements, Hong Kong is showing its desire not to be seen as a tax haven. In this context, the Double Taxation Convention could encourage French investment in its territory by refusing to apply these mechanisms. The contract provides that residents or owners of stable establishments in a given territory can benefit from tax credits from the other territory to avoid double taxation. For Hong Kong or France, the tax credit collected for the other territory cannot exceed the amount of tax imposed on the company. More details can be found in the press release and presentations: consulfrance-hongkong.org/16-Dec-2011-Comprehensive-Double details of the Hong Kong/France CDTA are available on the website of the Department of Internal Revenues: www.ird.gov.hk/eng/pdf/Agreement_France_HongKong.pdf Signing of the agreement between France and Hong Kong in October 2010 (in French): consulfrance-hongkong.org/La-France-et-Hong-Kong-signent-un comprehensive double taxation agreement has been concluded between Hong Kong and the following countries (with "in-force" data): The following information provides brief information on some important double taxation agreements signed by SArt. In August 2006, the Chinese and Hong Kong authorities signed an agreement to avoid double taxation, which aims to guarantee tax debt and tax savings to investors and taxpayers in both localities. The updated contract reduced the withholding tax from 20% to 15% for Hong Kong residents who received dividends from uk real estate investment trusts. In addition, withholding tax is limited to 3% for Hong Kong residents who collect royalties and interest from the United Kingdom, instead of the non-contract rate of 20%.
The Hong Kong CDTA in the United Kingdom replaces existing limited double taxation agreements for airline revenues and shipping revenues.