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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country :Hong Kong: Agreement

The Hong Kong Special Administrative Region (SAR) came into existence on 1 July 1997. Although Hong Kong is now part of the People’s Republic of China, it is not covered by the terms of the agreement between the United Kingdom and China.

A comprehensive agreement (SI 2010/2974), together with a Protocol which must be read with the agreement, entered into force on 20 December 2010 and has effect:

a) In the United Kingdom for corporation tax from 1 April 2011 and for income tax and capital gains tax from 6 April 2011;

b) In Hong Kong from 1 April 2011.

If using the HMRC Intranet, the agreement can be viewed through the “New treaties/protocols in force” link on the sidebar. On the HMRC web-site, searching for “Treaties in force Hong Kong” will provide a link to the treaty.

Prior to the comprehensive agreement having effect, there were two agreements between the United Kingdom and Hong Kong which covered, respectively, air and shipping transport (see DT9210 and DT9211).

The text of the Tax Treaty can be found via