asia-pacific-corridors

name	asia-pacific-corridors
description	OpenAccountants tax and accounting reference for INTL: asia pacific corridors. Use for cross-border questions in INTL (tax year ).
license	AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)
metadata	{"source":"openaccountants","jurisdiction":"INTL","category":"cross-border","quality":"source-cited draft","openaccountants_url":"https://openaccountants.com/skills/asia-pacific-corridors","obligation":"OTHER"}

Asia-Pacific Treaty Corridors — Withholding Tax Rates

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

Quick Reference

Field	Value
Jurisdiction	Asia-Pacific region
Corridors Covered	SG-AU, SG-IN, SG-JP, SG-HK, JP-AU, JP-IN, AU-NZ, IN-UAE, KR-JP, HK-UK, MY-SG
Number of Corridors	11
Last Verified	May 2026
Key Note	Singapore and Hong Kong do not levy WHT on dividends. Hong Kong has no WHT on interest or royalties (except royalties to closely connected non-residents at 4.95%). India has WHT on all passive income categories including FTS.

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Singapore → Australia

Income Type	Treaty Rate	Treaty Article	Notes
Dividends	15%	Art 8(1)	SG does not impose dividend WHT domestically
Interest	10%	Art 9	SG domestic WHT on interest: 15%
Royalties	10%	Art 10	SG domestic WHT on royalties: 10%
Technical services	0%	Art 5	Business profits — no WHT without PE

Source: Singapore-Australia DTA (ratified, modified by MLI 19 July 2021). IRAS treaty table. Special provisions: Older treaty (original 1969). Australia applies 30% domestic WHT on dividends, reduced by treaty. Singapore has no domestic dividend WHT — treaty rate relevant only from Australian side. Modified by MLI with PPT. Last verified: May 2026

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Singapore → India

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — substantial (≥25% capital)	10%	Art 10	Lower rate
Dividends — portfolio	15%	Art 10	Standard rate
Interest — banks/FIs	10%	Art 11	SG bank receiving Indian interest
Interest — general	15%	Art 11	Standard rate
Royalties	10%	Art 12	Standard rate
Fees for technical services	10%	Protocol	Protocol provision

Source: Singapore-India DTAA. PwC Singapore and India WHT tables. Special provisions: India-Singapore is a high-volume corridor (SG is India's largest FDI source). FTS clause added by protocol. India requires Form 10F (Form 41 from 2026) + TRC. India domestic WHT: 20% on dividends, 20% on interest, 10% on royalties/FTS. LOB article exists. Last verified: May 2026

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Singapore → Japan

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — substantial (≥25% shares, 6 months)	5%	Art 10	Lower rate
Dividends — portfolio	15%	Art 10	Standard rate
Interest	10%	Art 11	Japan domestic WHT 15-20%
Royalties	10%	Art 12	Japan domestic WHT 20%
Technical services	0%	Art 7	Business profits — no WHT without PE

Source: Singapore-Japan DTA. PwC Singapore and Japan WHT tables. Special provisions: Japan domestic WHT on dividends is 15-20%. Treaty reduces substantially. 25% threshold for reduced dividend rate is higher than modern standard (usually 10%). 6-month holding period required. Last verified: May 2026

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Singapore → Hong Kong

Income Type	Treaty Rate	Treaty Article	Notes
Dividends	0%/5%/10%	Art 10	See below
Interest	0%/15%	Art 11	SG domestic: 15%; HK: 0%
Royalties	5%/10%	Art 12	Split by type
Technical services	0%	Art 7	Business profits — no WHT without PE

Notes on rates:

• Dividends: 0% if beneficial owner is a company holding ≥10% of capital; 5% if ≥10% voting power (different condition); 10% in other cases
• Interest: Treaty does not override HK's 0% (HK has no WHT on interest); SG WHT 15% reduced to treaty rate
• Royalties: 5% on copyright/literary/artistic; 10% on other royalties

Source: Singapore-Hong Kong DTA (CDTA). PwC Singapore WHT table. IRAS. Special provisions: Neither jurisdiction levies WHT on dividends domestically. HK has no general WHT on interest. HK's only royalty WHT (4.95%) applies to closely connected non-residents — treaty may reduce further. Key corridor for Asian holding structures. Last verified: May 2026

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Japan → Australia

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	10%	Art 10	JP domestic WHT 15-20%
Dividends — substantial (≥10% voting, 6 months)	0%/5%	Art 10	0% for ≥80%; 5% for ≥10%
Interest	10%	Art 11	Government interest exempt
Royalties	5%	Art 12	JP domestic WHT 20% reduced
Technical services	0%	Art 7	Business profits — no WHT without PE

Source: Japan-Australia Convention (2008, revised). PwC Japan WHT table. Special provisions: Modern treaty with 0% rate for ≥80% parent-subsidiary dividends. 5% rate for ≥10% holdings. Australia's franking credit system affects effective dividend taxation. Royalties at 5% reflect favourable treatment. Last verified: May 2026

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Japan → India

Income Type	Treaty Rate	Treaty Article	Notes
Dividends	10%	Art 10	Both portfolio and substantial
Interest	10%	Art 11	Standard rate
Royalties	10%	Art 12	Standard rate
Fees for technical services	10%	Protocol	Protocol provision

Source: Japan-India DTAA. PwC Japan and India WHT tables. ClearTax India. Special provisions: Flat 10% across all categories is unusual — no split between portfolio and substantial dividends. India FTS provision applies. India domestic WHT: 20% on most categories — treaty provides significant reduction. Bilateral investment flows are substantial (Japan is major FDI source for India). Last verified: May 2026

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Australia → New Zealand

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	15%	Art 10(2)(b)	NZ domestic WHT 30%
Dividends — substantial (≥10% voting)	5%	Art 10(2)(a)	Direct investment
Interest	10%	Art 11(2)	Government/FI interest may be exempt
Royalties	5%	Art 12(2)	All categories 5%
Technical services	0%	Art 7	Business profits — no WHT without PE

Source: Australia-New Zealand Convention signed 26 June 2009 (Paris). In force 2010. Special provisions: Trans-Tasman corridor — one of the closest economic relationships globally. CER (Closer Economic Relations) framework. Australia's franking credits affect dividend treatment. Both countries are OECD members. Modified by MLI. Last verified: May 2026

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India → UAE

Income Type	Treaty Rate	Treaty Article	Notes
Dividends	10%	Art 10(2)	Flat rate (2007 Protocol amendment)
Interest — banks/FIs	5%	Art 11(2)(a)	Bona fide banking business
Interest — general	12.5%	Art 11(2)(b)	All other interest
Interest — government	0%	Art 11(3)	Government/central bank exempt
Royalties	10%	Art 12(2)	Standard rate
Fees for technical services	N/A	—	No FTS article in treaty

Source: India-UAE DTAA signed 1992, amended by 2007 Protocol. India IT Act vis-a-vis treaty. Special provisions: UAE introduced 9% corporate tax in 2023 but maintains extensive exemptions. Treaty originally had 5%/15% dividend split — 2007 Protocol changed to flat 10%. No FTS article — fees for technical services taxed under domestic law (10% under IT Act) or business profits (Art 7). UAE does not withhold on outbound payments. Major corridor for NRI investment structures. Last verified: May 2026

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South Korea → Japan

Income Type	Treaty Rate	Treaty Article	Notes
Dividends — portfolio	15%	Art 10	Standard rate
Dividends — substantial (≥25% shares)	5%	Art 10	Higher threshold
Interest	10%	Art 11	Government interest exempt
Royalties	10%	Art 12	Standard rate
Technical services	0%	Art 7	Business profits — no WHT without PE

Source: South Korea-Japan Convention. PwC Japan WHT table. Special provisions: 25% threshold for reduced dividend rate reflects older treaty practice. Korea domestic WHT on dividends: 20%. Japan-Korea relations affect treaty administration. Both countries are major trading partners. Last verified: May 2026

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Hong Kong → UK

Income Type	Treaty Rate	Treaty Article	Notes
Dividends	0%/15%	Art 10	0% general; 15% UK REIT
Interest	0%	Art 11	HK has no domestic interest WHT
Royalties	3%	Art 12	Very low rate
Technical services	0%	Art 7	Business profits — no WHT without PE

Source: UK-Hong Kong DTA. HMRC treaty summary. Special provisions: HK does not levy WHT on dividends or interest domestically. Royalty rate of 3% is one of the lowest globally. UK domestic WHT on interest/royalties is 20% — treaty reduces to 0%/3%. Key corridor for financial services. Modified by MLI. Last verified: May 2026

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Malaysia → Singapore

Income Type	Treaty Rate	Treaty Article	Notes
Dividends	0%	Art 10	Neither country levies dividend WHT
Interest	10%	Art 11	MY domestic WHT 15%
Royalties	8%/10%	Art 12	Split by type
Technical services	0%	Art 7	Business profits — no WHT without PE

Source: Malaysia-Singapore DTA. PwC Singapore WHT table. IRAS. Special provisions: Historical ASEAN partners with deep economic integration. Malaysia abolished dividend WHT (single-tier system). Singapore has no dividend WHT. Interest reduced from MY domestic 15%. Royalties: 8% for copyright/literary/artistic; 10% for industrial/commercial. Last verified: May 2026

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Summary: Key Asia-Pacific Treaty Rate Comparison

Corridor	Dividends (substantial)	Interest	Royalties	FTS
SG → AU	15% (no split)	10%	10%	N/A
SG → IN	10% (≥25%)	10%/15%	10%	10%
SG → JP	5% (≥25%)	10%	10%	N/A
SG → HK	0% (≥10%)	0%/15%	5%/10%	N/A
JP → AU	0%/5%	10%	5%	N/A
JP → IN	10%	10%	10%	10%
AU → NZ	5%	10%	5%	N/A
IN → UAE	10%	5%/12.5%	10%	N/A
KR → JP	5% (≥25%)	10%	10%	N/A
HK → UK	0%	0%	3%	N/A
MY → SG	0%	10%	8%/10%	N/A

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PE Threshold Notes — Asia-Pacific

Corridor	Construction PE Threshold	Service PE	Notes
SG → AU	12 months	None	Standard OECD
SG → IN	90 days in any 12-month period	90 days	India's short PE threshold
SG → JP	12 months	None	Standard OECD
SG → HK	12 months	None	Standard OECD
JP → AU	12 months	None	Standard OECD
JP → IN	90 days	90 days	India's short PE threshold
AU → NZ	12 months	None	Trans-Tasman standard
IN → UAE	9 months	None specified	Between standard and India norm
KR → JP	12 months	None	Standard OECD
HK → UK	12 months	None	Standard OECD
MY → SG	12 months	None	ASEAN standard

India's 90-day PE threshold is a critical planning factor for all India-related corridors. Service providers should carefully track days spent in India.

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Domestic WHT Rate Comparison

For context, here are the domestic (non-treaty) WHT rates in each jurisdiction:

Jurisdiction	Dividends	Interest	Royalties	Notes
Singapore	0%	15%	10%	No dividend WHT
Hong Kong	0%	0%	4.95%	Minimal WHT regime
Japan	15-20%	15-20%	20%	High domestic rates
Australia	30%	10%	30%	Franking credits on dividends
New Zealand	30%	15%	15%	NRWT
India	20%	20%	10%	IT Act s.115A rates
South Korea	20%	20%	20%	High domestic rates
Malaysia	0%	15%	10%	Single-tier dividend system
UAE	0%	0%	0%	No WHT (9% CIT introduced 2023)

Treaty rates should always be compared against these domestic rates — the lower of treaty or domestic applies.

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Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Treaty rates are subject to change through protocol amendments and renegotiations. Always verify current treaty text before relying on any rate. All outputs must be reviewed by a qualified professional before filing or acting upon.

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Source: OpenAccountants — open tax Guides for AI, reviewed by named CPAs/CAs/EAs. Quality: source-cited draft. For always-current figures and named-accountant backing, connect the OpenAccountants MCP server (openaccountants-mcp).