Hong Kong Opens its Pillar 2 E-Filing Portal

On January 19, 2026, the Hong Kong Inland Revenue Department opened its E-filing portal for the submission of Top-Up Tax Notifications. This also includes User Guides, an e-demo and FAQs.

Top-Up Tax Notification

Schedule 63(5) of the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 provides that each Hong Kong constituent entity of an in-scope MNE group is required to file an annual notification (“top-up tax notification”). Separate top-up tax notifications are required for HK Constituent Entities (CEs), HK standalone Joint Ventures (JVs), a HK member of a JV group, or stateless CEs.

The top-up tax notification is required for notifying the Tax authority that an MNE group has come within the scope of the global minimum tax and HKMTT, as well as identifying the entity and jurisdiction from which Hong Kong will receive the GIR and the local entities for which the obligation to file the top-up tax return will be lifted when certain conditions are met.

The top-up tax notification is to be filed within 6 months after the last day of the reporting fiscal year.

An in-scope MNE group can appoint one designated local entity to file a top-up tax notification so as to relieve other Hong Kong constituent entities from the filing obligation.  This applies to HK CEs and HK members of JV groups. HK standalone JVs and stateless constituent entity must file their own top-up tax notifications.

Filing

The Top-Up Tax Notification is filed via the Pillar 2 E-filing Portal. Separate registration for a Pillar 2 account is not required and the Pillar 2 Portal is an extended function of the current Business Tax Portal (“BTP”). In-scope MNE groups will have to register their dedicated business accounts under the BTP for accessing the Pillar Two Portal (if not already registered). The individual authorised to submit top-up tax notifications and top-up tax returns has to use his/her e-cert (Organisational) with AEOI Functions for authentication.

The Guidance states that each MNE group, HK standalone JV or JV group will need to apply for a unique group code.

To obtain a group code, an “Application for Group Code in respect of Multinational Enterprise Group, HK Standalone JV or JV Group” (Form IR1485) should be submitted to the Hong Kong Revenue Department in paper form.