Taiwan is not Hong Kong: The ultimate barriers for the enactment of the “one country, two systems” principle

The white paper released in August 2022 by the Taiwan Affairs Office of the State Council and the State Council Information Office of the People's Republic of China (PRC) re-proposes the formula of “one country, two systems” (OCTS) for a peaceful “reunification” with Taiwan.

Since 1949, cross-Strait relations have evolved from military to peaceful confrontation. Domestic and international factors contributed to this shift. The PRC, although it has never excluded the use of force, has repeatedly and only put forward OCTS for a peaceful solution of the so-called Taiwan issue. However, the proposal did not receive much endorsement on the island. Considering the rising tensions in the Taiwan Strait and Beijing’s constant emphasis on it, this series investigates “one country, two systems”, the only peaceful proposal put forward by the PRC to end the conflict. 

This is the last article in the series dedicated to “one country, two systems”, analyzing why the principle has never been applied to Taiwan. After reviewing the innate differences between Taiwan and Hong Kong that explain why it was easier to apply it in the former British colony, the article moves to analyze the deep roots of Taiwan’s rejection of such a proposal. We point the finger to three factors: Taiwanese national identity, Taiwan’s democratization and the deep distrust towards Beijing.

The differences between Hong Kong and Taiwan

Beyond the structural limitations of “one country, two systems”, Taiwan differs from Hong Kong in many ways. Analyzing these decisive differences is crucial to understand why the formula proposed by Beijing could not be applied on the island.

“One country, two systems” is one of the PRC’s united front tactics, used to hide its real foreign policy objectives. Besides its structural weaknesses, the lack of guarantees preventing Beijing from withdrawing the granted status of autonomy and the current disagreement about the “one China” principle are crucial features that Taipei cannot accept.

First, Taiwan is geographically separated from the mainland. This characteristic saved the ROC for many years since 1949: the island is relatively easy to defend, and an amphibious landing is complicated. Moreover, unlike Hong Kong, Taiwan was never dependent on the mainland for resources, like food imports and water.

Second, the structures of domestic political power are different. The centralization of political power within the executive branch in Hong Kong, under British rule first and under the PRC authority after, contrasts with Taiwan’s constitutional democracy. In particular, Taiwan has been self-governing for over three decades. Any approach to unification would require radical changes in its political institutions and identity. The institutions and significant international ties that the ROC enjoys are lacking in Hong Kong, which has shifted from being a British Overseas Territory to being one of the PRC’s special administered regions. The process of handover was entirely negotiated by the British and Chinese governments, with some consideration given to the interests of the business community. The people of Hong Kong and its government that was not selected through direct electoral participation, played an extremely limited role in the Joint Declaration process. If a similar process had to take place in Taiwan, Taiwanese’ opinions would necessarily need to be taken into account.

Third, Taiwan has built sophisticated armed forces over the years. Taiwan’s army, beyond being modern and ready to fight, is by design structured to face the constant threat of a PRC invasion. Hong Kong never really had its own armed forces: it was under the protection of the British Army and of the Hong Kong Police Force. Despite several reassurances that in case of reunification Taiwan would be allowed to keep its armed forces, it seems highly unlikely that this could really happen since for their nature Taiwan’s armed forces represent a threat to the PRC. On the other hand, it is even more unlikely that Taiwan would dismiss its armed forces or allow an incorporation into the PLA.

Fourth, both Taiwan and Hong Kong have developed distinct and multiple political identities that are separate from the mainland. An increasing share of the population defines itself as Hongkonger or Taiwanese while the people that define themself as Chinese are declining significantly, especially among the younger generations. The discrepancies with the PRC reality that Hong Kong experienced before 1997 and Taiwan since 1949 have much to do with it. However, there was no significant movement or consensus for Hong Kong independence in the years prior or directly following the handover. It was PRC’s assertiveness that provoked a rise in Hong Kong’s national identification. In Taiwan, on the opposite, the independence movement has a history that goes back decades and emerged not only as a reaction to PRC’s policies and threats but also, and mainly, as a reaction to the KMT authoritarian regime. But more importantly, Taiwan nationalism has been integrated into the state’s institutions, whereas nothing similar happened in Hong Kong. Furthermore, the strength of nationalism in both cases varies greatly. Taiwanese nationalism, due its longer history, demonstrates an ideological sophistication that Hong Kong nationalism still lacks, mainly because of its recent development as an organized movement and of its character being mainly popular.

The ultimate barriers to a peaceful unification

In addition to the structural flaws of “one country, two system” and the innate differences between Hong Kong and Taiwan, there are three main barriers to a peaceful reunification between the PRC and Taiwan: Taiwanese national identity, Taiwan’s democratization and a deep distrust towards Beijing.

Since the late 1980s, Taiwanese national identity has been the major cleavage in the island’s society and politics. The Kuomintang tried initially after 1949 to install on the island a strong top-down cultural identity with mainland China, which at the end failed. As a reaction, the institutionalized manners of distinction contributed to the emergence of a Taiwanese ethnic identity and to a political opposition to the KMT and to reunification. As a result, Taiwan’s democratization movement and the pro-independence movement became closely linked. Political openness and democratization sparked a debate on the island’s identity and future. Peculiar social mores have developed on the island creating the perception of a social majority that has increasingly fewer common elements with the Mainlanders. This split and the emotional attachment to the mainland lost importance from the 1990s due to the end of the KMT oppressive regime, intermarriages between mainlanders and Taiwanese, and generational change, with fewer people witnessed the authoritarian regime or fled the mainland. This identity mutation is also visible at the political level. The pan-Blue coalition, of which the KMT is the leading party, accepting the 1992 Consensus, still believes that Taiwan, although with its own peculiarity, is ethnically, historically and culturally part of the Chinese nation. On the other side, the pan-Green coalition, of which the DPP is the leading party, tries to stress Taiwan’s uniqueness and to promote Taiwanese nationalism. The Tsai Administration’s innovative approach, shared to some extent by the KMT, promotes Taiwan’s national identity as founded on the belief and attachment to its democratic institutions. It promotes an institutional identity (zhì dù rèn tóng, 制度认同). This civic nationalism could prove to be more inclusive since it is not based on legal and territorial definitions of predetermined culture, blood line or origins.

The most important impact of democratization has been to make Taiwan’s government, and its PRC policy, more responsive to the concerns of the native Taiwanese. Taiwan’s democratization, linking the impact of Taiwan’s policies to the preferences of its voters, explains in large part the little progress made by the PRC toward “peaceful reunification” since the 1980s. It is thus public opposition to “one country, two systems” the primary obstacle to reunification. Taiwanese growing identity makes the acceptance of the “one China'' principle less possible. Furthermore, giving a seat at the negotiation table to the Taiwanese people not only brought the chances of reunification to a new low but also made the PRC fear that Taiwan will declare independence. Moreover, Taiwan’s democratic political system undermines the Chinese Communist Party’s (CCP) claim that democracy is a Western concept that is not suitable for Chinese characteristics, while the island’s successful capitalist economy undermines Beijing’s claim that the Party and socialism are the best alternative for Chinese people to achieve prosperity and wealth. This could endanger the stability of the PRC’s political system. The trend toward a separate Taiwan identity poses a further challenge for PRC’s leadership because national identity cannot be easily influenced, as Beijing hopes to do. The CCP therefore seeks to emphasize cultural similarities, ethnic equivalence, and common economic interests, while acknowledging that Taiwan has distinctive and different characteristics due to the years of separation from the mainland.  

Perhaps, the major issue preventing negotiations is Taiwan’s distrust towards Beijing’s proposals. How can we expect Taiwanese, who have fought for and built a successful democracy, to believe in, or even find attractive, the “one country, two systems” proposal? The PRC’s dismissal of the same principle in Hong Kong is a powerful warning. Taiwan would have to give up its political sovereignty and put at risk its higher standard of living in exchange for no legal or effective guarantee preventing the PRC from eliminating the promised autonomy. An agreement would entail trusting the PRC Central Government. An unlikely possibility. Taipei has all to lose and little to gain. We have also to consider that Beijing has not had an excellent record on its policies towards autonomous regions. The Agreement for the Peaceful Liberation of Tibet with the Tibetans, an early version of “one country, two systems”, signed in 1951, recognized PRC sovereignty over Tibet in exchange for the preservation of Tibet’s political, military, and religious structures. Notwithstanding, as in Hong Kong, every promise was broken. The Agreement for the Peaceful Liberation of Tibet, as the Joint Declaration, was meant to buy time and achieve a smooth transfer of power. Beijing then needed a justification to end the agreements. The 1959revolt in Tibet parallels the 2019 protests in Hong Kong. The latter led to a violent repression, the dissolution of the Kashag government and the suppression of any autonomy with the establishment of Tibet Autonomous Region in 1965. The former led to the transformation of the city’s political institutions. Tibet and Hong Kong are vivid examples that Taipei sees as its own future in case of reunification. If a deal on the model of “one country, two systems” could even be signed over Taiwan, Beijing’s top priority would still be to maintain control over Taipei’s executive and legislative power. This means that political parties that advocate for Taiwanese identity or express critical views of CCP’s policies would not be allowed to participate anymore in the island’s political life. The inevitable outcome will be a shift backwards in Taiwan’s level of democracy. The PRC's willingness to overall control is unlikely to propose a model for reunification that would protect Taiwan’s civil and political rights, its rule of law or independent judiciary. Even if such a possibility should occur, it is even more unlikely that Beijing would maintain that status in perpetuity.