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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Hong Kong: Dividends

Dividends are taxable in the source state at a rate of 15% if they are payable by a property investment vehicle, such as a United Kingdom Real Estate Investment Trust, unless the beneficial owner is a pension scheme.

Dividends from a property investment vehicle paid to a pension scheme and all dividends other than those paid by a property investment vehicle are exempt from tax in the source state.

The exemptions provided by the treaty are not given if the dividend is effectively connected (see INTM153110 fifth sub-paragraph) with a permanent establishment which the United Kingdom resident recipient has in Hong Kong.