Details of the income and capital gains tax treaty and protocol between Hong Kong and United Kingdom, signed on 21 June 2010, have become available. The treaty was concluded in the English language and generally follows the OECD Model Convention. The maximum rates of withholding tax are: -   0% on dividends; 15% on dividends paid out of the Uinted Kingdom by real estate investment trusts; -   0% on interest, except where the anti-treaty shopping provisions in the treaty apply; and -   3% on royalties. Deviations from the OECD Model include that: -   A building site, a...