Hong Kong-Armenia tax treaty signed

Hong Kong Tax Newsflash

Published date: 28 June 2024

Hong Kong SAR (HK) signed a Comprehensive Double Tax Agreement (CDTA) with Armenia on 24 June 2024. Armenia is one of the economies participating in the Belt and Road Initiative.  This is the 50th CDTA concluded by HK.

Below is a comparison of the withholding tax rates applicable to dividends, interest and royalties, under the respective domestic tax law and the HK-Armenia CDTA:





HK non-CDTA rate



4.95% / 16.5%NB1

Armenia non-CDTA rate


0% / 10% NB2


HK-Armenia CDTA rate

0% / 5% NB3



NB1: The 4.95% rate generally applies. If the royalty is paid to an associated entity and the intellectual property has been owned by a person carrying on business in HK, 16.5% applies.  If the taxpayer is eligible for two-tiered tax rates, 2.475% (or 8.25% if higher rate) applies on the first HKD 2 million of assessable profits and 4.95% (or 16.5% if higher rate) on the remaining amount.

NB2: The 10% rate generally applies.  If the interest is paid on a foreign currency denominated government bond, 0% applies.

NB3: 0% if the beneficial owner is a company which holds directly at least 10% of the capital of the company paying the dividends throughout a 365-day period; 5% in all other cases.

The HK-Armenia CDTA will come into force after the completion of ratification procedures by both jurisdictions.  The CDTA can be downloaded from this link.

Tax Newsflash is published for the clients and professionals of Deloitte Touche Tohmatsu. The contents are of a general nature only. Readers are advised to consult their tax advisors before acting on any information contained in this newsletter.

If you have any questions, please contact our professionals:


Doris Chik
Tax Partner
+852 2852 6608

Carmen Cheung
Senior Tax Manager
+852 2740 8660

Kiwi Fung
Tax Manager
+852 2258 6162

International and M&A Tax

National Leader

Vicky Wang
Tax Partner
+86 21 6141 1035

Hong Kong

Anthony Lau
Tax Partner
+852 2852 1082

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