Hong Kong Tax Newsflash

The Comprehensive Double Taxation Agreement (CDTA) for Hong Kong-Mauritius has come into force on 23 June 2023, after completion of the relevant ratification procedures.  The CDTA will be in effect starting from the year of assessment 2024/25 in Hong Kong and from 1 July 2023 in Mauritius.

The Hong Kong-Mauritius CDTA was signed in November 2022 and can be downloaded from this link.  Please also refer to our previous Hong Kong Tax Newsflash (Issue 164) for the key features of the CDTA. 

In addition to the provision of more beneficial withholding tax rates applicable to dividends, interest and royalties, the Hong Kong-Mauritius CDTA provides beneficial treatment on capital gains.  For example, capital gains derived by a Hong Kong investor from the disposal of shares of a Mauritius company (except land-rich¹) are generally exempt from tax in Mauritius under the CDTA. 

^{1 Capital gains derived by a Hong Kong resident from the alienation of shares of a company deriving more than 50% of its asset value directly or indirectly from immovable property situated in Mauritius.} 

^{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.}

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Authors

Doris Chik
Tax Partner
+852 2852 6608
dchik@deloitte.com.hk

Carmen Cheung
Tax Manager
+852 2740 8660
carmcheung@deloitte.com.hk

Kiwi Fung
Tax Manager
+852 2258 6162
kifung@deloitte.com.hk

International and M&A Tax

National Leader
Vicky Wang
Tax Partner
+86 21 6141 1035
vicwang@deloitte.com.cn 

Hong Kong
Anthony Lau
Tax Partner
+852 2852 1082
antlau@deloitte.com.hk