Hong Kong and Nigeria enter into tax pact (with photos)

On 13 Jul 2026, the Secretary for Financial Services and the Treasury, Mr Christopher Hui, convened an online bilateral meeting with Mr Taiwo Oyedele, Nigeria’s Minister of Finance and Co-ordinating Minister for the Economy. Mr Hui executed a comprehensive avoidance of double taxation agreement ("CDTA") on behalf of the Hong Kong Special Administrative Region Government.

Agreement Execution and Strategic Context

Hong Kong’s Financial Centre Positioning

Mr Hui underscored Hong Kong’s standing as a premier international financial centre, citing leadership in cross-boundary wealth management, global competitiveness, and tax policy. Concurrently, to establish Hong Kong as a global gold trading, clearing, and reserve hub, the Government initiated trial operations for a new central clearing and settlement system for gold, supported by targeted measures to foster a modern, full-chain gold trading ecosystem.

Economic Significance and CDTA Benefits

Highlighting Nigeria’s status as Africa’s most populous nation with the third-largest GDP, Mr Hui noted its role in the Belt and Road Initiative and as a key African trading partner for Hong Kong. The expansion of the CDTA network, particularly with Belt and Road economies, offers Hong Kong enterprises enhanced tax certainty and relief from double taxation during overseas expansion. This framework incentivizes the centralisation of fund management, asset allocation, and risk management within Hong Kong. This instrument marks the 59th CDTA concluded by Hong Kong and the fourth this year.

Taxation Mechanisms and Rates

The CDTA delineates taxing rights between the jurisdictions. Under the agreement, tax paid by Hong Kong residents in Nigeria is creditable against Hong Kong tax liability on the same income, subject to the Inland Revenue Ordinance (Cap. 112) ("IRO"). Furthermore, withholding tax rates applicable to Hong Kong residents on dividends and interest, and to Hong Kong companies on royalties, are reduced from 10 per cent to 7.5 per cent.

Implementation and Ratification

The CDTA becomes effective upon completion of ratification procedures by both parties. In Hong Kong, the Chief Executive in Council will enact an order under the IRO, which shall be submitted to the Legislative Council for negative vetting. Further particulars may be accessed via the Inland Revenue Department’s website.