1. Interest arising in a Contracting Party and beneficially owned by a resident of the other Contracting Party shall be taxable only in that other Contracting Party.

2. The competent authorities of the Contracting Parties shall by mutual agreement settle the mode of application of paragraph 1.

3. The term “interest” as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a
     right to participate in the debtor’s profits, and in particular, income from government securities and income from bonds or debentures, including premiums
     and prizes attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as interest for the purpose of this
     Article.

4. The provisions of paragraph 1 shall not apply if the beneficial owner of the interest, being a resident of a Contracting Party, carries on business in the other 
    Contracting Party in which the interest arises, through a permanent establishment situated therein, and the debt-claim in respect of which the interest is 
    paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.

5. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of
    the interest exceeds, for whatever reasons, the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such
    relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable
    according to the laws of each Contracting Party, due regard being had to the other provisions of this Agreement.

 The above information is the wording of the article dealing with the withholding tax on interest of the tax treaty between The Netherlands and Hong Kong.  Please note that the ultimate withholding tax rate may differ from the treaty rate, for instance as consequence of domestic anti-abuse legislation, provisions of the treaty protocol, etc. Before you use this information we therefore strongly recommend that you consult us to determine the accurate withholding tax rate for your specific situation. If you require our follow up, you can contact us via e-mail or call us at our offices: Ph. + 31 (10) 2010466.