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The PRC appears to hold the Joint Declaration which it does treat as a valid treaty to have become fully executed, meaning that all its terms have been performed. Hong Kong has been handed over and much of the substance of the document is to be found in its first annex (Annex I) which is – and the PRC emphasises this aspect – entitled an ‘Elaboration by the Government of the People's Republic of China of its basic policies regarding Hong Kong’. The UK takes a different view, treating as substantive treaty commitments the PRC’s (own) elaboration of Chinese policies in the third paragraph and in Annex I. The roots of this controversy run deep and have their origin in the treaty negotiations.
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