Revenue eBrief No. 206/18
06 December 2018
Interest Withholding Tax: advance clearances under double taxation treaties and Hong Kong corporate treasury centres
Tax and Duty Manual Part 08-03-06, which deals with the operation of Interest Withholding Tax, has been updated to:
- set out how advance clearance, under certain double taxation treaties, can be obtained to avoid the need to operate Interest Withholding Tax under section 246, in situations where that withholding tax would be refundable in full
- extend the Hong Kong withholding tax exemption to interest paid to a Hong Kong company taxed under the profits tax concession for corporate treasury centres.