On 22 Apr 2026, the Government signed the 57th Comprehensive Avoidance of Double Taxation Agreement ("CDTA") with Barbados. In response to a Legislative Council question, the Secretary for Financial Services and the Treasury outlined the status of the tax treaty network, including 57 signed agreements, 17 under negotiation, and future expectations. The Government emphasized focusing on Belt and Road jurisdictions, reviewing standards against OECD BEPS requirements, and allocating resources to expedite negotiations and promote Hong Kong as a headquarters economy.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
SPOTLIGHT ON
FAMILY OFFICES
Expansion of the Comprehensive Double Taxation Agreement Network
On 22 Apr 2026, the Government signed the 57th Comprehensive Avoidance of Double Taxation Agreement ("CDTA") with Barbados in March 2026. In a written reply to Dr the Hon Hoey Simon Lee, the Secretary for Financial Services and the Treasury, Mr Christopher Hui, confirmed the proactive expansion of the CDTA network. Since the establishment of the Hong Kong Special Administrative Region Government, Hong Kong has entered into CDTAs with major trading partners, starting with the Chinese Mainland in 1998 and the first overseas jurisdiction, Belgium, in 2003. As of mid-April 2026, Hong Kong has signed CDTAs with 57 tax jurisdictions, 12 of which were signed by the current-term Government, with 17 jurisdictions under negotiation. Depending on content and complexity, three to four CDTAs are expected to be signed this year.
Strategic Economic Initiatives and Investment Promotion
According to 2025 figures, 15 of Hong Kong's top 20 major trading partners have signed CDTAs, accounting for over 75 per cent of total trade value. To attract enterprises and facilitate 'going global' via Hong Kong, the Government will expand the CDTA network with a focus on Belt and Road ("B&R") Initiative jurisdictions. The CEDB and the Belt and Road Office will continue to organise the annual Belt and Road Summit, reach out to agencies, organise missions, and encourage roadshows. Invest Hong Kong will assist enterprises, including those along the B&R and in innovation and technology, while OASES will engage technologically leading enterprises. To enhance Hong Kong's role as a key base for Corporate Treasury Centres ("CTCs"), the Government will provide additional tax incentives and flexibility, with an action plan to be announced in mid-2026.
Compliance with International Tax Standards and Legal Framework
The Government reviews and updates CDTAs to ensure conformity with prevailing international tax standards and provide sufficient safeguards. In 2015, the OECD introduced the Base Erosion and Profit Shifting ("BEPS") package, and the Government implemented the Multilateral Convention through local legislation in 2022 to modify earlier CDTAs. Recent CDTAs incorporate provisions meeting the Convention's standards, with withholding tax rates generally on par with major trading partners or more favourable. CDTAs clearly set out taxing rights, residents, taxes covered, elimination of double taxation, dispute resolution, and information exchange arrangements to provide tax certainty and legal protection.
Administrative Oversight and Resource Allocation
The Financial Services and the Treasury Bureau and the IRD are responsible for CDTA network expansion duties. Major officers include one Principal Assistant Secretary for Financial Services and the Treasury, one Assistant Commissioner of Inland Revenue (D2 level), and seven administrative, assessor, and executive officers. To cope with increasing workload, the IRD created the Assistant Commissioner post in June 2023 to strengthen directorate level support. To meet operational needs, the Government will arrange internal deployment or increase manpower as appropriate.
View the full article:Source
