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Hong Kong SAR ChinaInland Revenue Department

Hong Kong signs 61st tax treaty with Laos, capping dividends at 5-8%

Laos withholding on dividends falls to 5% for qualifying companies and 8% otherwise, with interest and royalties at 5%; the treaty is signed but not yet in force.

By Taxxa AI OyPublished 29 October 2026

Tax

Hong Kong and Laos signed a comprehensive avoidance of double taxation agreement (CDTA)IRD in Hong Kong on 29 October 2026IRD. The Acting Secretary for Financial Services and the Treasury, Joseph Chan, signed for Hong Kong and Deputy Minister of Finance Soulivath Souvannachoumkham signed for Laos. It is Hong Kong's 61st CDTAIRD, the sixth signed this year and the 16th signed by the current-term Government. Hong Kong has now signed CDTAs with seven ASEAN member states, covering more than 70 per cent of ASEAN's total population and gross domestic product.

The agreement allocates taxing rights between the two places so investors can better assess their tax liabilities from cross-border activity and avoid double taxation. Tax paid by Hong Kong residents in Laos in accordance with the agreement is allowed as a credit against Hong Kong tax on the same incomeIRD, subject to the Inland Revenue Ordinance (Cap. 112) and limited to the Hong Kong tax computed on that income.

For dividends, Laos withholding, currently 10 per centIRD, is capped at 5 per cent of the gross amount where the beneficial owner is a company resident in the other party holding directly at least 15 per cent of the payer's capital throughout a 365-day period including the payment date, ignoring ownership changes from a corporate reorganisation. The cap is 8 per cent otherwiseIRD. Dividends paid to the Hong Kong Government, the Hong Kong Monetary Authority, the Exchange Fund or an agreed wholly or mainly government-owned entity are exempt from Laos tax, with mirror exemptions for Lao government bodies including the Bank of the Lao PDR.

For interest, also currently 10 per centIRD, the source-state cap is 5 per cent of the gross amountIRD, with the same government and central-bank exemptions. Royalties are capped at 5 per centIRD, covering copyright including software, patents, trade marks, designs, plans, secret formulas or processes, and industrial, commercial or scientific information. There is no separate technical fees article for Laos. Where the holding, debt claim or royalty right is effectively connected with a permanent establishment or fixed base the beneficial owner has in the source state, the business-profits or independent-personal-services provisions apply instead of these caps.

The agreement is signed but not yet in forceIRD IRD. It enters into force on the later of the two written notifications confirming completion of each side's proceduresIRD. In Hong Kong the Chief Executive in Council will make an order under the Inland Revenue Ordinance, to be tabled at the Legislative Council for negative vetting. The Inland Revenue Department records the CDTA signature as 29.10.2026 with the section 49 order, entry into force and effective date all Pending or In progress, alongside the pre-existing 2009 air services agreement, and Laos no longer appears in the negotiations-commenced table. Once in force it has effect in Hong Kong for any year of assessment beginning on or after 1 April in the calendar year after entry into forceIRD, and in Laos for withholding on income derived on or after 1 January in that next yearIRD and for other taxes for years beginning on or after that dateIRD.

Legal basis: the Agreement between the Government of the Hong Kong Special Administrative Region of the People's Republic of China and the Government of the Lao People's Democratic Republic for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance, Articles 10, 11, 12, 22 and 28 with its Protocol, as implemented by an order under section 49 of the Inland Revenue Ordinance (Cap. 112).

Map Hong Kong-Laos dividends, interest and royalties against the 5%/8%, 5% and 5% source-state caps and hold any treaty relief claim until the agreement enters into force.

Sources

Hong Kong SAR ChinaInland Revenue Department

Hong Kong signs 61st tax treaty with Laos, capping dividends at 5-8%

Laos withholding on dividends falls to 5% for qualifying companies and 8% otherwise, with interest and royalties at 5%; the treaty is signed but not yet in force.

By Taxxa AI OyPublished 29 October 2026

Tax

Map Hong Kong-Laos dividends, interest and royalties against the 5%/8%, 5% and 5% source-state caps and hold any treaty relief claim until the agreement enters into force.