In-Depth Analysis Report on the 'First-Line/Second-Line' Tax Policy for the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone

Based on the collected information, I will prepare an in-depth analysis report on the tax policy for the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone.

On January 14, 2026, the Ministry of Finance, General Administration of Customs, and State Taxation Administration jointly issued the Notice on Tax Policies Concerning the Import and Export of Goods in the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone (Cai Guan Shui [2026] No. 1), which will officially take effect on February 10, 2026 [1]. This move is to implement the Development Plan for the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone (Guo Fa [2023] No. 12) and support the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone to jointly build an international science and technology innovation highland with the Hong Kong Park [2].

The Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone is located in the southern part of Futian District, Shenzhen, adjacent to Hong Kong, with a total area of approximately 3.89 square kilometers. Among them, the Shenzhen Park covers 3.02 square kilometers (including 1.35 square kilometers of the Futian Free Trade Zone and 1.67 square kilometers of the Huanggang Port Area), and the Hong Kong Park covers approximately 0.87 square kilometers [3]. As one of the major cooperation platforms in the Guangdong-Hong Kong-Macao Greater Bay Area under the national 14th Five-Year Plan Outline, the cooperation zone undertakes the important mission of Shenzhen-Hong Kong collaborative innovation and scientific and technological achievement transformation.

According to the policy, the customs supervised area under specific closed management in the Hetao Shenzhen Park adopts the ‘first-line/second-line’ segmented management [1][2]:

• Enterprises registered in the customs supervised area with independent legal person status
• Public institutions engaged in scientific research in the customs supervised area
• Science and technology-related private non-enterprise units registered in the customs supervised area

Self-used scientific research goods imported through the ‘first-line’ by the above-mentioned eligible entities are exempt from import tariffs, import value-added tax, and consumption tax [1].

• Duty-free scientific research goods and their R&D finished products entering the mainland through the ‘second-line’ shall go through customs procedures in accordance with relevant regulations on imported goods
• Eligible entities shall pay the import taxes on imported materials
• If import taxes have been paid or supplemented in accordance with regulations at the ‘first-line’ or within the customs supervised area, no additional import taxes shall be paid in this link [2]

The policy clarifies that eligible entities recognized by the Shenzhen Municipal People’s Government will be included in the ‘white list’ and filed with the Ministry of Finance, General Administration of Customs, and State Taxation Administration [1]. A customs electronic ledger will be established for duty-free imported scientific research goods, which will be managed by information-based and intelligent means, and will not be managed as specific duty-reduced or exempted goods. In addition, the supervision period for duty-free imported equipment and their spare parts for maintenance, utensils, documents, and specimens shall follow the supervision period for imported duty-reduced or exempted goods; for duty-free imported consumables, animals and their products, and other spare parts that are consumed in scientific research and do not form R&D finished products, eligible entities may be exempt from supplementing import taxes upon application, and the supervision will be lifted in accordance with regulations [2].

The most direct impact of this tax policy is to significantly reduce the cross-border flow costs of scientific research goods between Shenzhen and Hong Kong [1][2]. For R&D institutions established in the Hetao Shenzhen Park, self-used imported scientific research equipment, consumables, reagents, etc. can enjoy import tax exemption, which will greatly reduce the initial R&D investment costs of enterprises. According to the analysis of PwC, the Shenzhen Park of the Hetao Cooperation Zone had previously implemented a preferential corporate income tax rate of 15% and the preferential individual income tax policy of ‘Hong Kong residents taxed under Hong Kong rules’ [4]. The introduction of this goods import and export tax policy forms a more complete preferential tax system, which will significantly enhance the park’s investment attractiveness to high-tech enterprises and R&D institutions.

From the perspective of investment costs, a medium-sized biomedical R&D enterprise may import R&D consumables and equipment worth tens of millions of RMB each year. Based on the previous average comprehensive import tax rate of 10-15%, the tax relief amount can reach millions to tens of millions of RMB. This is a considerable cost saving for start-up technology enterprises.

The implementation of the policy will effectively promote mutually beneficial cooperation between Shenzhen and Hong Kong, and jointly advance scientific and technological innovation and industrial development [1]. The Hetao Shenzhen Park and the Hong Kong Park are separated only by a river. The facilitation of ‘first-line’ management will realize the convenient flow of scientific research goods between Shenzhen and Hong Kong, enabling enterprises to make full use of resources in both regions: Hong Kong can leverage its advantages as an international financial center to attract international talents and capital, while Shenzhen can provide complete industrial chain support and a broad market hinterland.

As of July 2025, the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone has completed 13 specialized parks, gathering 8 R&D centers of Fortune 500 companies, 10 national-level major scientific research platforms, 13 scientific research projects of Hong Kong universities, over 200 high-end scientific research projects, and more than 15,000 scientific researchers [3]. Since the opening of the Hong Kong Science Park Shenzhen Branch in September 2023, more than 68 technology enterprises have settled in as of August 2025 [3]. The implementation of the tax policy will further accelerate this industrial agglomeration effect.

The Hetao Shenzhen Park is located in Futian District, adjacent to the Lok Ma Chau Hetao Area of Hong Kong, and its development will drive the collaborative development of surrounding regions. As an important part of the park, the Futian Free Trade Zone will directly benefit from the policy dividends. In addition, the development of the park will also radiate and drive the scientific and technological innovation and modern service industry development of surrounding regions such as the Shenzhen Central Area and the Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone.

From the perspective of the industrial chain, the active R&D activities in the park will drive the development of supporting service industries such as inspection and testing, technical consulting, and professional services, and will also promote the prosperity of life service industries such as surrounding commerce, catering, and accommodation.

The introduction of this policy is an important measure by the state to promote the high-quality development of the Guangdong-Hong Kong-Macao Greater Bay Area [1][2]. According to the Outline Development Plan for the Guangdong-Hong Kong-Macao Greater Bay Area and the Opinions of the Central Committee of the Communist Party of China and the State Council on Supporting Shenzhen in Building a Pilot Demonstration Zone of Socialism with Chinese Characteristics, the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone is positioned as a national-level major scientific and technological innovation cooperation platform, which is an important carrier for exploring the Shenzhen-Hong Kong collaborative development model, innovating scientific and technological management mechanisms, and promoting the efficient and convenient flow of factors.

The policy clearly will help support Hong Kong’s integration into the overall national development and build an international science and technology innovation highland [1]. This reflects the country’s strategic considerations in promoting Shenzhen-Hong Kong scientific and technological cooperation under the framework of ‘One Country, Two Systems’, and creates favorable conditions for the collaborative development of the two regions through tax policy innovation.

The introduction of the tax policy for the Hetao Shenzhen Park will have a positive impact on the industrial park REITs market. Looking at the listed industrial park REITs, the underlying assets of products including Shekou Industrial Park REIT, Zhangjiang Everbright REIT, Zhongguancun REIT, and Hefei High-Tech REIT are all science and technology industrial parks [5]. The implementation of the Hetao policy verifies the sustainability and expansion trend of preferential tax policies for science and technology parks, which helps to enhance investors’ confidence in industrial park REITs.

From the perspective of valuation, the valuation earnings multiple of industrial park REITs is closely related to the expected growth of park rental income [5]. Positive factors such as increased enterprise occupancy and enhanced expectations of rent increases brought by the preferential tax policy will support the valuation of industrial park REITs.

For industrial park operators such as China Merchants Shekou, Zhangjiang High-Tech, and Zhongguancun, the development model of the Hetao Shenzhen Park has a demonstration effect [5]. These enterprises can learn from the policy innovation experience of the Hetao Park to promote policy breakthroughs and industrial agglomeration in the parks they operate.

As the sponsor of Shekou Industrial Park REIT, China Merchants Shekou’s industrial park layout in Shenzhen is expected to benefit from the spillover effect of the overall policy dividends in the Greater Bay Area. As the operator of the Zhangjiang High-Tech Park, Zhangjiang High-Tech can refer to the Shenzhen-Hong Kong collaboration model of the Hetao Park to explore new paths for Shanghai-Hong Kong scientific and technological cooperation.

From the perspective of capital market performance, the valuation of the science and technology park sector is affected by multiple factors, including the macroeconomic environment, industrial policies, rental levels, and operational efficiency. The introduction of the tax policy for the Hetao Shenzhen Park is another important policy dividend following the release of the Development Plan for the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone (released in August 2023) and the Development Outline for the Hong Kong Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone (released in November 2024) [3][6].

From the performance of the REITs market, the performance of industrial park REITs diverged in 2025 [5]. Lingang Innovation and Manufacturing REIT had the best operational efficiency, while the first batch of listed REITs such as Shekou Industrial Park REIT, Zhangjiang Everbright REIT, and Zhongguancun REIT faced pressure from declining occupancy rates. The implementation of the Hetao policy is expected to provide a new catalyst for the fundamental improvement of industrial park REITs.

The public offering REITs market continued to expand in 2025, and industrial park REITs remained an important category [5]. According to statistics from Rosefinch Fund, multiple industrial park REITs are waiting to be listed in 2025, including Beijing Jinyu Intelligent Manufacturing Workshop REIT and Beijing Yizhuang Industrial Park REIT. The successful practice of the Hetao Shenzhen Park policy provides a policy model for the asset securitization of industrial parks. It is expected that more industrial park operators will consider realizing asset exit and reinvestment through REITs.

• China Merchants Shekou (001979.SZ)
  : As the sponsor of Shekou Industrial Park REIT, it has rich experience in industrial park operation in Shenzhen and is expected to benefit from the policy dividends in the Greater Bay Area
• Zhangjiang High-Tech (600895.SH)
  : Zhangjiang High-Tech Park is a benchmark for domestic high-tech parks, and can explore Shanghai-Hong Kong cooperation by learning from the Hetao model
• Zhongguancun (000931.SZ)
  : The operator of the Zhongguancun Science and Technology Park, benefiting from the improvement of the overall policy environment for science and technology parks

• Shenzhen Properties (000011.SZ)
  : Registered in Futian, Shenzhen, it may benefit from the radiation effect of the Hetao Park
• Shenzhen Energy (000027.SZ)
  : A Shenzhen-based energy enterprise with extensive business layout in the Guangdong-Hong Kong-Macao Greater Bay Area

• Shekou Industrial Park REIT (180101.SZ)
• Zhangjiang Everbright REIT (508000.SH)
• Zhongguancun REIT (180108.SZ)
• Hefei High-Tech REIT (180102.SZ)

Shenzhen-Hong Kong scientific and technological innovation cooperation will drive the development of industries such as venture capital, technology transfer, and technology services, and relevant enterprises are expected to benefit.

The implementation effect of the preferential tax policy depends on the implementation of specific implementation rules, including the identification criteria for eligible entities and the definition of the scope of duty-free goods.

The development of science and technology parks is closely related to the macroeconomic environment. Economic downturn may lead to a decline in enterprise leasing demand.

With the increase in the supply of science and technology parks in the Greater Bay Area, competition for talents and enterprises among parks may intensify.

The liquidity of industrial park REITs is relatively weak, and they may face the risk of discount in the secondary market.

The tax policy for the Hetao Shenzhen Park, together with the previously introduced preferential corporate income tax (15% tax rate) and preferential individual income tax (“Hong Kong residents taxed under Hong Kong rules”), forms a complete preferential tax policy system [4]. This reflects the country’s thinking of “policy first trial” in the construction of the Guangdong-Hong Kong-Macao Greater Bay Area, and creates favorable conditions for Shenzhen-Hong Kong collaborative development through tax policy innovation.

The Ministry of Finance, General Administration of Customs, and State Taxation Administration clearly stated that they will optimize and adjust the list of duty-free scientific research goods according to actual needs and regulatory conditions [1]. This means that the policy has certain flexibility and expansion space, and is expected to be further optimized and improved according to the development needs of the park in the future.

According to the Development Outline for the Hong Kong Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone issued by the Hong Kong SAR Government, the Hong Kong Park will be developed in two phases. The floor area of the first phase has been doubled to 1 million square meters, mainly including the Artificial Intelligence and Data Science Zone, Life and Health Technology Zone, and New Technology and Advanced Manufacturing Zone [6]. The Hong Kong Park is expected to officially enter the operation stage in 2026, and the first batch of tenants will start to settle in the second half of 2026.

The collaborative development of the two parks in Shenzhen and Hong Kong will form an innovative cooperation model of “scientific research in Hong Kong, transformation in Shenzhen”, and the tax policy of the Hetao Shenzhen Park provides institutional guarantee for this.

The introduction of the ‘First-Line/Second-Line’ tax policy for the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone is an important measure by the state to promote the high-quality development of the Guangdong-Hong Kong-Macao Greater Bay Area. By exempting import taxes on scientific research goods, this policy significantly reduces the R&D costs of enterprises, enhances the investment attractiveness of the park, and will effectively promote scientific and technological collaborative innovation between Shenzhen and Hong Kong.

From an investment perspective, this policy will directly benefit the science and technology park sector, mainly reflected in three aspects: first, the industrial agglomeration effect of industrial parks will be enhanced; second, the fundamentals of industrial park REITs are expected to improve; third, relevant industrial park operators will face development opportunities. It is recommended that investors focus on the investment opportunities of industrial park REITs and industrial park operators, while paying attention to risk factors such as policy implementation and macroeconomy.

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[1] Ministry of Finance of the People’s Republic of China. Notice on Tax Policies Concerning the Import and Export of Goods in the Shenzhen Park of the Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone Issued by the Ministry of Finance and Other Two Ministries. https://gss.mof.gov.cn/gzdt/zhengcejiedu/202601/t20260114_3981849.htm

[2] Xinhua News Agency. Tax Policies Concerning the Import and Export of Goods in the Hetao Shenzhen Park Clarified. http://www.xinhuanet.com/fortune/20260114/4cde239394354ef893749794195580e7/c.html

[3] Hong Kong Exchanges and Clearing Limited. Issuance of Offering Circular. https://www.hkexnews.hk/listedco/listconews/sehk/2025/0930/2025093000600_c.pdf

[4] PwC China. Implementation of Preferential Corporate Income Tax and Individual Income Tax Policies in the Hetao Cooperation Zone. https://www.pwccn.com/zh/china-tax-news/2024q1/chinatax-news-feb2024-6.pdf

[5] Rosefinch Fund. Public Offering REITs Quarterly Report (Q2 2025). https://www.rosefinchfund.com/upload/pdf/1753942664272-gongmuREITsjibao-2025nian2jidu.pdf

[6] Government of the Hong Kong Special Administrative Region. Legislative Council Question No. 12: Hetao Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone. https://www.info.gov.hk/gia/general/202412/11/P2024121100296.htm