Hong Kong and Kyrgyz Republic enter into tax pact (with photos)

On 02 Mar 2026, the Secretary for Financial Services and the Treasury of Hong Kong, Mr Christopher Hui, and the Minister of Economy and Commerce of the Kyrgyz Republic, Mr Bakyt Tolomushevich Sydykov, signed a comprehensive avoidance of double taxation agreement ("CDTA") at an online bilateral meeting.

This CDTA is the 56th agreement for Hong Kong, showcasing the HKSAR Government's consistent efforts in expanding its CDTA network. Mr Hui emphasized the importance of this agreement in enhancing Hong Kong's business and investment appeal and consolidating its status as an international economic and trade center.

Mr Hui presented the advantages of Hong Kong as an international financial hub and its efforts to establish it as a regional gold reserve center. He highlighted how this CDTA will allocate taxing rights between the two jurisdictions, enabling investors to better assess potential tax liabilities and avoid double taxation, thereby creating a more attractive business environment.

Under the terms of the agreement, any tax paid by Hong Kong residents in the Kyrgyz Republic will be credited against tax payable in Hong Kong. Additionally, the withholding tax rate on dividends received by Hong Kong companies holding at least 20% of the share capital of the dividend-paying company will be reduced from up to 10% to 5%, and the maximum withholding tax rate on interest and royalties will be reduced from 10% to 8%.

The CDTA will become effective following the completion of ratification procedures by both sides. In Hong Kong, the Chief Executive will issue an order under the Inland Revenue Ordinance, which will be tabled at the Legislative Council for negative vetting. Detailed information regarding the CDTA is available on the Inland Revenue Department website.