Hong Kong

Abstract

While primary attention on the effect of international agreements on the allocation of taxing rights is on bilateral double tax conventions, a host of non-tax treaties also contain taxation measures. These include both multilateral and bilateral agreements, a large number of which are associated with international organizations. This paper reviews all the treaties apart from Hong Kong's tax treaties that prescribe tax outcomes and override the domestic Hong Kong tax laws. The source of Hong Kong's non-tax treaties with tax measures is unique, with agreements inherited from the UK, its colonial overseer, China, the sovereign state to which it belongs, and treaties it has entered into on its own.