The Belgian Minister of Finance has clarified recently the application of the participation exemption and the definition of "beneficial owner" under the Belgium-Hong Kong tax treaty on income and capital of 10 December 2003 (the treaty).
Hong Kong only taxes domestic profits and not foreign profits. Under the treaty, the withholding tax on dividends is 0% if the beneficial owner at the time of the payment has held directly for an uninterrupted period of at least 12 months shares …