TAIWAN will treat Hong Kong as a ''special zone distinct from mainland China'' after Beijing gains control on July 1, 1997, a government spokesman said yesterday. Cheng An-kuo, director of the Department of Hong Kong and Macau Affairs Office of the Mainland Affairs Council (MAC), said the definition would be embodied in legislation that would govern Taiwan's relations with Hong Kong and Macau after the two territories revert to Beijing. Mr Cheng said MAC would convene a cross-ministerial meeting to examine specific proposals for articles for the law and decide on a preliminary draft. Seminars will then be held in Taiwan, Hong Kong and Macau to discuss the draft. He said a draft statute should be ready to be submitted to the cabinet for discussion by the end of this year or early next year. After a review by the cabinet and concerned ministries, the draft statute should be sent to the Legislative Yuan by the end of 1994. Mr Cheng said MAC expected the Legislative Yuan to pass the third reading of the bill by the end of 1996. He said the allocation of two years for review and passage by the Legislative Yuan was necessary as ''conditions can change very fast in Hong Kong and Macau and it would be very awkward if the law was passed, say in January 1996, and substantial changes were needed afterwards''. The new law will be patterned after the ''Regulations on Relations between the peoples of the Taiwan Area and the Mainland China Area'', effective September 18, 1992, which sets out the legal basis in Taiwan for all aspects of interaction between people on Taiwan and mainland China. But Mr Cheng noted that the Hong Kong-Macau relations act would differ in several key aspects. For example, air and sea links between Taiwan and the two territories would not be considered as ''direct air or sea links with the mainland''. Mr Cheng said: ''We hope to maintain the current state of air and sea transit linkages with Hong Kong after 1997.''