Hong Kong was a British colony until 1997 when it was returned to China. Today, Hong Kong remains a common law jurisdiction, distinct from Mainland China, and enjoys a high degree of autonomy. Before 1997, Hong Kong followed the British doctrine of restrictive sovereign immunity, under which a foreign sovereign is not immune from claims arising out of commercial activities. China, however, has espoused the more traditional doctrine of absolute sovereign immunity, under which a foreign sovereign is always immune from suit, whether or not the claim arose from commercial activities.
Absolute, Restrictive, or Something More: Did Beijing Choose the Right Type of Sovereign Immunity for Hong Kong?,
Emory Int'l L. Rev.
Available at: https://scholarlycommons.law.emory.edu/eilr/vol26/iss2/15