Global Daily Tax News, Hong Kong, Slovenia Sign New Double Tax Pact, (Sep 8, 2026)

Hong Kong and Slovenia signed a new comprehensive double tax agreement on September 4, 2026.

The Secretary for Financial Services and the Treasury, Christopher Hui, said: "This is the 60th CDTA that Hong Kong has concluded, the 15th one that the current-term Government has signed, and the fifth one this year. It marks a new milestone of the HKSAR Government's efforts in proactively expanding Hong Kong's CDTA network."

The agreement will cap the maximum rate of withholding tax that may be charged at source to 10 percent for dividends, down from as much as 25 percent, and lower the rate for interest and royalties income, which also face rates of up to 25 percent, to five percent.

The agreement will incorporate the BEPS minimum standards, including a new preamble that states that the DTA is not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance, or treaty shopping. Further, the agreement will include provisions to counter treaty abuse, prevent the artificial avoidance of permanent establishment status, neutralize the effects of hybrid mismatch arrangements, and improve dispute resolution mechanisms.

Hui added that the territory has concluded negotiations on a comprehensive DTA with Kazakhstan, which will be signed after the completion of both countries' domestic procedures. Negotiations will also be launched on an agreement with Uzbekistan this year.