Global Daily Tax News, Hong Kong Adds To FAQs On China DTA Residence Issues, (Dec 24, 2025)

Hong Kong's Inland Revenue Department has released guidance on individual residence issues under the territory's double tax agreement with Mainland China.

The tax agency has issued four new answers to frequently asked questions in relation to residence issues under the DTA, discussing the rules under the treaty where a person with domiciliary registration in the Mainland moves and works in Hong Kong for more than 180 days under a talent admission scheme, where the taxpayer is contemporaneously resident in both China and Hong Kong.

The FAQs further discuss whether such a taxpayer's treatment under the double tax agreement differs where, additionally:

• the taxpayer owns property in Hong Kong and China;

• the taxpayer frequently works in the Mainland, as well as in Hong Kong;

• the taxpayer works from Hong Kong during weekdays and returns to China at the weekend.