Double Taxation Agreement Switzerland Hong Kong

Double Taxation Agreement between Switzerland and Hong Kong: A Comprehensive Guide

The Double Taxation Agreement (DTA) signed between Switzerland and Hong Kong aims to avoid the incidence of double taxation on the same income in both jurisdictions. This means that taxpayers who have income flowing from both territories would only have to pay tax on that income once, instead of doing so in both jurisdictions.

The DTA is an essential framework that forms the basis for cross-border investment by ensuring that the income earned from these investments is taxed fairly and in compliance with the laws of each jurisdiction. The agreement also encourages the flow of capital between the two territories by eliminating any tax barriers that could hinder investment.

What is the Scope of the Double Taxation Agreement?

The DTA between Switzerland and Hong Kong covers a broad range of income types, including business profits, dividends, interest, royalties, and capital gains. It also covers pensions and government service payments.

Taxation of Business Profits

The DTA provides specific rules for the taxation of business profits earned by enterprises that operate in both jurisdictions. For instance, if a Swiss company has a subsidiary in Hong Kong, the profits earned by that subsidiary would be taxed in Hong Kong. The profits will then be exempt from Swiss tax, providing that the Swiss company owns no more than 50% of the subsidiary`s share capital.


Under the DTA, dividends that are paid by a company resident in one jurisdiction to a resident of the other will be subject to a maximum withholding tax of 15%, provided that the shareholder owns at least 25% of the paying company`s share capital. In all other cases, the withholding tax is capped at 10%.


For interest income, the DTA provides for a maximum withholding tax rate of 10%.


Royalties received by a resident of one jurisdiction but derived from the other jurisdiction are subject to a maximum withholding tax rate of 3%.

Capital Gains

The DTA provides that capital gains arising from the disposal of shares in a company are taxed only in the country of residence of the shareholder unless the shares derive more than 50% of their value from immovable property located in the other jurisdiction.

What are the Benefits of the DTA?

The DTA between Switzerland and Hong Kong is beneficial to investors and businesses located in both territories. Some of its benefits include:

– Avoidance of double taxation: The agreement ensures that taxpayers do not have to pay tax twice on the same income.

– Encourages cross-border investment: By eliminating tax barriers, the DTA ensures that capital can flow between the two jurisdictions, which can lead to more investment opportunities.

– Provides a stable tax environment: The agreement provides a stable tax environment, which is essential for investors, as they can plan and implement their investments without worrying about tax changes.


The Double Taxation Agreement between Switzerland and Hong Kong provides a framework for the taxation of income that flows between the two jurisdictions. It is essential for businesses and investors who operate in both territories, as it avoids the incidence of double taxation. The agreement provides stability, certainty, and an opportunity for cross-border investment. As a professional, it is essential to be well-versed in such agreements to ensure that any articles on the topic are accurate, informative, and easy to understand.

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