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Following ratification by the respective governments of both sides, the Fourth Protocol to the double tax arrangement between Hong Kong and Mainland China (HK-China DTA) is now in retroactive effect as of 29 December 2015.

The changes introduced under the Fourth Protocol are designed to realise two objectives: first, they are intended to boost Hong Kong’s attractiveness as a platform for investment into China via targeted tax incentives. Second, they counteract abuse of benefits under the HK-China DTA and facilitate information exchange by tightening anti-abuse provisions and expanding the scope of taxes covered under the information exchange provision.
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