On 2 October 2019, the Hong Kong’s Chief Executive in Council made an order under the Inland Revenue Ordinance (Cap. 112) to implement the Fifth Protocol to the Comprehensive Avoidance of Double Taxation Arrangement with the Mainland (Mainland CDTA) that was signed on 19 July 2019.

The protocol incorporates into the Mainland CDTA a new teachers and researchers article to provide tax relief to qualified Hong Kong and Mainland teachers and researchers working on the other side, as well as measures to prevent tax treaty abuse to ensure that the Mainland CDTA follows the latest international tax standard. The order will be tabled at the first sitting of the Legislative Council after the publication in the Gazette for negative vetting. The agreement will enter into force after both Hong Kong and the respective partner has completed their ratification procedures.