- 1. (a) Salaries, wages and other similar remuneration paid by the Government of a Contracting Party or a political subdivision or a local authority of a Contracting Party to an individual in respect of services rendered to that Party or subdivision or authority shall be taxable only in that Party.
- (b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting Party if the services are rendered in that Party and the individual is a resident of that Party who:
- (i) in the case of the Hong Kong Special Administrative Region, has the right of abode therein and in the case of the United Kingdom, is a national thereof; or
- 2. The provisions of Articles 14, 15 and 16 shall apply to salaries, wages and other similar remuneration in respect of services rendered in connection with a business carried on by the Government of a Contracting Party or a political subdivision or a local authority of a Contracting Party.
Citation to select or copy
United Kingdom / Hong Kong; HMRC, Synthesised text of the Multilateral Instrument and the 2010 UK-Hong Kong Double Taxation Agreement — in force; edition Official synthesis; HMRC updated 15 August 2025; article 18; English; source role publisher-synthesis; Official publisher synthesis, not an authentic signed original or current-law certification. Publisher qualifications remain source text and searchable.; unreviewed source text, current applicability unverified; /editions/gb-hk-2010-hmrc-synthesis-html-reserve-v1/en/articles/article-18/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.
Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
Source & edition
HMRC, Synthesised text of the Multilateral Instrument and the 2010 UK-Hong Kong Double Taxation Agreement — in force
Digest scope: retained online-source capture; no PDF binary verification
Publisher role and language
Official publisher synthesis, not an authentic signed original or current-law certification. Publisher qualifications remain source text and searchable.
Official publisher synthesis; authentic Convention and MLI texts take precedence; not assistant consolidation.
Actual supplied body languages: English. A language named by an instrument is not a supplied translation.
Edition
Official synthesis; HMRC updated 15 August 2025
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Languages recorded in source metadata: English. This is not a promise of available text or a translation.
Edition notes and known limitations
Official HTML text capture, not Original PDF; human wording and current-law certification not claimed.
Block IDs are navigation aids, never invented legal paragraph numbers. Native extraction can flatten ordered-list styling; only printed source labels are retained.
Complete preamble, closing and all supplied integral protocol/notes are retained separately and searchable within this source.
Hong Kong is a separate tax jurisdiction, not presented as a sovereign country. Source heading Article12 is preserved verbatim, not silently corrected.
Publisher synthesis, not an authentic treaty instrument. MLI replacement text and explanations are retained; original boxes/layout are not reproduced. Authentic Convention and MLI texts take precedence.
Source authority, text completeness and currentness still require human review.
Publisher prints Article12 without a space. Exact source heading retained; navigation identifies 12 without changing source wording.