GloBE Country Guide: Hong Kong

Summary

Status	Draft Law
Law	Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 of December 27, 2024 In April 2025, the Hong Kong Government proposed a number of Committee Stage Amendments to the Bill. The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was passed by the Legislative Council on May 28, 2025. It now needs to be signed by the Chief Executive and published in the Official Gazette.
Effective Date	Financial years beginning on or after January 1, 2025
IIR	Yes (2025)
UTPR	To apply from a later date
QDMTT	Yes (2025)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour, Transitional UTPR Safe Harbour (when in effect), Simplified Calculations Safe Harbour and the QDMTT Safe Harbour

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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