On 4 September 2026, the Hong Kong Inland Revenue Department (IRD) announced the signing of a Comprehensive Double Taxation Agreement (CDTA) with Slovenia, marking Hong Kong’s 60th tax treaty. The agreement follows the OECD Model Tax Convention and incorporates the latest BEPS minimum standards, including principal purpose test (PPT) and mandatory binding arbitration provisions. It will enter into force after both sides complete ratification procedures, with provisions taking effect from the following tax year. The treaty covers taxes on income, including profits tax, salaries tax, and property tax in Hong Kong, and corresponding taxes in Slovenia.
Key Takeaways
- Expanded Treaty Network: The Slovenia CDTA brings Hong Kong’s total tax treaty count to 60, strengthening its position as an international financial hub and providing certainty for cross-border investors.
- BEPS-Compliant Provisions: The treaty includes anti-abuse measures such as the Principal Purpose Test (PPT) and a simplified limitation on benefits clause, aligning with OECD BEPS Action 6 recommendations.
- Dispute Resolution Mechanism: For the first time in a Hong Kong treaty, mandatory binding arbitration is included, offering taxpayers a robust mechanism to resolve double taxation disputes within a defined timeframe.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement