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.
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

Sign into your account to access this analysis

Not a Subscriber?

If you haven’t got a subscription you can sign up below

Already a Subscriber?

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.

Cookie	Duration	Description
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Corporate Investments and Pillar Two

Switzerland Opens Consultation for Applying OECD GIR Provisions

Japan Issues Regulations for its QDMTT from April 1, 2026

Hong Kong Updates Global Minimum Tax Bill for OECD Administrative Guidance and Other Updates