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| Hong Kong, Liechtenstein Sign Comprehensive DTA |
by Mary Swire, Tax-News.com, Hong Kong
Monday, August 16, 2010
On August 12, Hong Kong signed its 14th comprehensive agreement for the avoidance
of double taxation (DTA), incorporating the latest Organisation for Economic
Cooperation and Development standard on exchange of information for tax purposes.
The Special Representative for Hong Kong Economic and Trade Affairs to the
European Union, Mary Chow, signed the agreement on behalf of Hong Kong, while
the Liechtenstein Prime Minister, Klaus Tschutscher, signed on behalf of his
government.
The DTA sets out clearly the allocation of taxing rights between the jurisdictions,
and the relief on tax rates on different types of passive income and capital
gains. As such, it currently applies to Hong Kong’s profits, salaries
and property taxes, and, for Liechtenstein, the personal and corporate income,
corporation, real estate capital gains, wealth and coupon taxes.
Hong Kong or Liechtenstein residents receiving dividends, interest or royalties,
or earning capital gains, from the other country will be subject to tax only
in their resident jurisdiction. Similarly, under the DTA, Hong Kong or Liechtenstein
airlines operating international flights, or international shipping businesses,
will also only be taxed in their resident country.
The DTA will come into force after the completion of ratification procedures
on both sides. In the case of Hong Kong, an order to be made by the Chief Executive
in Council under the Inland Revenue Ordinance is required. The order is subject
to negative vetting by the Legislative Council.
A comprehensive report in our Intelligence Report series,
examining in depth the situation of offshore transparency and secrecy in a number
of the most prominent jurisdictions, is available in the Lowtax Library at
http://www.lowtaxlibrary.com/asp/subs_reports.asp
and a description of the report can be seen at
http://www.lowtaxlibrary.com/asp/description_report2.asp
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intelligence reports cover every important aspect of 'offshore' and international
tax-planning in depth, including banking secrecy, the EU's savings tax
directive, offshore funds, e-commerce, offshore gaming and transfer pricing.
Reports are available for immediate downloading or as subscription
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