Hong Kong and Norway: Income tax treaty signed
Entry into force pending completion of ratification procedures in both countries
Hong Kong and Norway on December 16, 2025, signed a comprehensive income tax treaty, which provides for a reduced withholding tax rate for dividends and a tax exemption for business profits in the absence of a permanent establishment (PE).
The treaty will enter into force after completion of the ratification procedures in both countries. The existing tax agreement between Hong Kong and Norway on shipping transportation income will cease to have effect upon the entry into force of the treaty.
Articles 8 and 13(3) of the treaty dealing with income related to international shipping and air transportation will have effect from the date the treaty enters into force. The remaining treaty articles will take effect from calendar year 2027 in Norway and year of assessment 2027/2028 (which begins on April 1, 2027) in Hong Kong the earliest.
Read a December 2025 report prepared by the KPMG member firm in Hong Kong