South Africa Hong Kong Double Tax Treaty

On the 20th October 2015 the double tax treaty between South Africa and Hong Kong entered into force. The Treaty applies from 1 January 2016 for South Africa and 1 April 2016 for Hong Kong.

Interesting points to note about the treaty are:

  1. Withholding taxes on dividends are reduced to 5% with the requisite shareholding;
  2. No CGT on sale of shares in a property holding company with less than 50% interest in property, this is less than the domestic South African rule.
  3. The entry into force of this treaty is interesting given the continuing investment into Africa by China and its extensive use of the Hong Kong treaty.

Should you require further information then please contact:

Peter Todd |

Telephone: +230 650 4030