Abstract: This paper presents a case study analysis of the Hong Kong Special Administrative Region (HKSAR) New Zealand (NZ) Double Tax Agreement (DTA) in the context of the DTA negotiating practices of the two jurisdictions. By way of background it first examines HKSAR’s emerging DTA program and contrasts this with the approach to negotiating DTAs that is adopted by NZ. The paper concludes that the HKSAR NZ DTA is an important milestone for the two jurisdictions, with the interplay with the People’s Republic of China (PRC) a potentially challenging factor that needs to be incorporated into the practical ramifications of this new HKSAR NZ DTA.

This paper by Professor Adrian Sawyer Professor Adrian Sawyer Professor of Taxation in the UC Business School, University of Canterbury AIIFL Profile › can be downloaded: here .