The fifth amending pending protocol to the 2006 income tax arrangement between China and Hong Kong was signed on 19 July 2019. Changes made by the protocol include: 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 determine its residence for the purposes of the arrangement through mutual agreement, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors, and if...