Hong Kong (China)
A. Progress in the implementation of the minimum standard
Hong Kong (China) has 39 tax agreements in force, as reported in its response to the Peer Review questionnaire. Two of those agreements, the agreements with Belarus* and Finland, comply with the minimum standard.
Hong Kong (China) joined the MLI in 2017, listing 36 tax agreements.1
Hong Kong (China) is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2
The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.
B. Implementation issues
No jurisdiction has raised any concerns about their agreements with Hong Kong (China).
Notes
← 1. The agreement with Belarus*, which is already compliant, is also listed under the MLI.
← 2. For 35 of its agreements listed under the MLI, Hong Kong is implementing the preamble statement (Article 6 of the MLI). For 34 of its agreements listed under the MLI, Hong Kong is implementing the PPT (Article 7 of the MLI). Hong Kong made a reservation pursuant to Article 6(4) not to apply Article 6(1) with respect to agreements, which already contain the relevant preamble language. One of Hong Kong’s agreements is within the scope of this reservation. Hong Kong made a reservation pursuant to Article 7(15) (b) not to apply Article 7(1) with respect to agreements, which already contain a PPT. Two of Hong Kong’s agreements are within the scope of this reservation.