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Posted Wed, 28 Jun 2023 05:18:53 GMT by SunnyD
Hi, I note that there is a Double Tax Arrangement in place between UK and Hong Kong. As I understand from the DTA, a person resident in Hong Kong places a deposit in a bank in UK and earns interest therefrom. He may be taxed in Hong Kong for the interest income from UK by invoking the DTA Article 11 and it follows that he will not be liable to income tax in UK. I should be grateful if you would confirm whether my understanding is correct. Thank you.
Posted Tue, 04 Jul 2023 11:06:14 GMT by HMRC Admin 5 Response
Hi,

Article 11(1) of the double taxation agreement advises the interest arising in the UK and paid to a resident of Hong Kong, may be taxed in Hong Kong.  c
Clause 11(2) goes on to state that interest may also be taxable in the UK, unless at least one of the conditions in paragraph 11(3) are met.  
Clause 11(3)(ii) relates to an individual.  This means that if the beneficial owner of the UK interest is an individual, resident in Hong Kong, then the interest is only taxable in Hong Kong. 
Take a look at the guidance in this link:
UK/HONG KONG DOUBLE TAXATION AGREEMENT AND PROTOCOL

Thank you
 

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