Hong Kong and Slovenia have concluded a comprehensive tax treaty that cuts withholding tax rates on dividends, interest and royalties for cross-border payments.
The Hong Kong Financial Services and the Treasury Bureau completed negotiations on a comprehensive avoidance of double taxation agreement (CDTA) with Slovenia on 4 September 2026. Secretary Christopher Hui signed the accord on behalf of the Hong Kong Special Administrative Region Government alongside Ambassador Boštjan Malovrh of Slovenia.
The agreement represents Hong Kong’s 60th CDTA and marks the fifth such treaty concluded in 2026 alone. The current-term Government has now signed 15 CDTAs overall, reflecting an accelerated push to expand Hong Kong’s international tax cooperation network.
Withholding tax rates and bilateral benefits
Under the treaty framework, tax credits apply to Hong Kong residents on income earned in Slovenia, subject to provisions in the Inland Revenue Ordinance.
Slovenia’s withholding tax on dividends paid to Hong Kong residents drops to a maximum of 10%, down from 25%. Withholding taxes on interest and royalties fall to 5% maximum from the previous 25% rate.
The Slovenia CDTA will enter into force after both sides complete their respective legislative procedures. In Hong Kong, the Chief Executive in Council will issue an order under the Inland Revenue Ordinance for tabling at the Legislative Council under negative vetting provisions.
