Pillar 2 Compliance: Hong Kong
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On September 26, 2025, Hong Kong updated its Pillar 2 guidance to include information on its Pillar 2 Portal, applications for Group Codes and mandatory e-filing of profit tax returns for Pillar 2 groups.
On June 6, 2025, the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 was published in the Official Gazette. The Bill includes an Income Inclusion Rule (IIR) and a domestic minimum tax from January 1, 2025.
In April 2025, the Hong Kong Government proposed a number of Committee Stage Amendments to the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024. This includes amendments for the January 2025 and June 2024 OECD Administrative Guidance.
On December 27, 2024, the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was published in the Official Gazette. The Bill includes an Income Inclusion Rule (IIR) and a domestic minimum tax from January 1, 2025.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Hong Kong for accounting periods beginning on or after January 1, 2025. Updated for the draft legislation issued on December 31, 2024.
On October 30, 2024, the Hong Kong government released the outcome statement following the previous consultation into the introduction of the GloBE rules.
In Today’s 2023 Budget, Hong Kong’s Financial Secretary confirmed that Hong Kong will implement the Pillar Two Global Minimum Tax from 2025.
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