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Hong Kong – Ireland Double Tax Treaty

Updated on Wednesday 20th December 2017

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Hong-Kong-Ireland-Double-Tax-Treaty.jpgThe agreement on double taxation and the prevention of fiscal evasion was signed by Hong Kong and Ireland on 22 June 2010; it had come into effect on 10 February 2011 and it enforced in Hong Kong from 1 April 2012. The Hong Kong – Ireland double taxation agreement (DTA) offers advantageous tax regimes for both countries. 

Taxes covered under the Hong Kong – Ireland agreement 

When opening a company in Hong Kong, you should know that the agreement covers the following taxes in Hong Kong Special Administrative Region:
profit tax;
salaries tax;
property tax.
The following taxes will be covered by the agreement in the case of Ireland:
income tax;
income levy;
corporation tax;
capital gains tax.

Provisions of the Hong Kong – Ireland DTA

The agreement offers provisions for companies in Hong Kong and Ireland, which are related to the following: permanent establishment of a business, income from immovable property, business profits, shipping/air transport, taxes on dividends, interest, royalties and capital gains. 
Interest withholding tax will not exceed 10% of the gross amount of the interest; if it arises in a contracting state (Hong Kong) and is paid to a resident of the other state (Ireland), it may be taxed in the other state; interest can also be taxed in the country where it arises, if the beneficial owner of the interest is a resident of the other contracting state. 
Royalties arising in Hong Kong, that have to be paid to a resident of Ireland can be taxed in Ireland; royalties can also be subjected to tax where they arise (Hong Kong), only if the owner of the royalties is a resident in the other contracting country (Ireland). In this latter situation, the withholding tax on royalties will not exceed 3% of the gross amount of the royalties. Our consultants in company formation can provide further details on the taxes imposed by the new Hong Kong – Ireland DTA
If you want to open a company in Hong Kong you should know that the furnishing of services are also included in the definition of a permanent establishment, even if the company it is represented in Hong Kong only by the employees. If the activity (including consultancy services) continues for more than 183 days in a year, according to the new DTA, it is considered to be a permanent establishement. 
If you need information about company registration in Hong Kong or further presentation on the Hong Kong – Ireland double taxation agreement, please contact our specialists in company formation

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Roger Pay is the Managing Director of our company and an experienced company incorporation specialist. He will help you open your company in Hong Kong as fast as possible. 

Call us now at +852 35651861 to set up an appointment with our company formation experts in Hong Kong. As our client, you will benefit from the joint expertise of local lawyers and consultants for opening an offshore company in Hong Kong.

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- prompt response to your inquiry (maxim 24 hours);

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I would definitely recommend the team of company formation experts at to every foreign businessman that wants to establish a business here. Quick responses and excellent personalized approach to clients!

Mihai Cuc, Partner of MHC Law Firm

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