The fifth amending pending protocol to the 2006 income tax arrangement between China and Hong Kong was signed on 19 July 2019. Changes made by the protocol include:
- The replacement of the preamble in line with BEPS standards;
- The amendment of Article 4 (Resident) to provide that if a person other than an individual is a resident of both jurisdictions, the competent authorities will determine its residence for the purposes of the arrangement through mutual agreement, having regard to its plac…