Hong Kong and Kyrgyzstan signed their first comprehensive tax treaty on 2 March 2026, reducing withholding tax rates on dividends, interest, and royalties while providing tax credits to prevent double taxation for residents of both jurisdictions.
The Hong Kong Inland Revenue Department (IRD) has announced that an income and capital tax treaty was signed with Kyrgyzstan on 2 March 2026, marking the first comprehensive tax agreement between the two jurisdictions.
Under the agreement, the treaty applies to Hong Kong profits tax, salaries tax, and property tax. On the Kyrgyzstan side, it covers corporate income tax, personal income tax, and property tax.
In accordance with this DTA, any tax paid by Hong Kong residents in Kyrgyzstan will be allowed as a credit against the tax payable in Hong Kong in respect of the same income in accordance with the provisions of the Inland Revenue Ordinance (Cap. 112) (IRO).
In addition, if a Hong Kong company holds at least 20% of the share capital of the dividend-paying company, the Kyrgyzstan’s withholding tax rate on such dividends, currently at up to 10%, will be reduced to 5%; while the maximum withholding tax rate on interest and royalties received by Hong Kong residents, currently at 10%, will be reduced to 8%.
This DTA will come into force after completion of ratification procedures by both sides.
