Details of the income tax treaty and protocol between Hong Kong and Japan, signed on 9 November 2010, have become available. The treaty was concluded in Chinese, Japanese and English languages, each text having equal authenticity. In the case of divergence, however, the English text prevails. The treaty generally follows the OECD Model Convention. The maximum rates of withholding tax are: -   10% on dividends generally, but 5% if the beneficial owner is a company owning directly or indirectly at least 10% of the voting power of the company paying the dividends for a period of 6 months ending...