The Hong Kong Inland Revenue Department has announced that the fifth amending pending protocol to the 2006 income tax arrangement between China and Hong Kong entered into force on 6 December 2019. The protocol was signed on 19 July 2019 and includes the following changes:
- 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 de…