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.
Pillar 2 Portal
The updated Guidance notes that a Pillar Two Portal is being developed to facilitate the submission of the relevant notifications and returns and will be launched in phases from January 2026 onwards.
Under Schedule 63(5) of the Minimum Tax Ordinance, each Hong Kong constituent entity of an in-scope MNE group will be required to file an annual notification (“top-up tax notification”). The top-up tax notification is to be filed within 6 months after the last day of the reporting fiscal year.
A top-up tax return is required to be submitted by the GIR filing deadline. However, Sections 63(6) and 63(8) permit group filing (broadly where the return is filed by a designated local entity or a UPE or designated filing entity and an information exchange agreement is in place if the entity is not resident in Hong Kong).
The Guidance states that the Pillar Two 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. 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.
Application for Group Codes
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.
E-Filing
Pillar 2 in-scope entities are included in Phase 1 of the mandatory e-filing of profits tax returns. This applies to years of assessment that begins on or after 1 April 2025
An entity is required to e-file its profits tax return for an applicable year of assessment if both of the following two conditions are met:
Condition 1: Entity is a Pillar 2 entity of an MNE group
This applies to a Pillar 2 entity of an MNE group for the fiscal year (a fiscal year that is beginning on or after 1 January 2025) corresponding to the applicable year of assessment. A Pillar 2 entity is a constituent entity, joint venture, JV subsidiary, stateless constituent entity or stateless permanent establishment.
Condition 2: MNE group is an in-scope MNE group
This condition is met if any of the following applies:
-The MNE group to which the Pillar 2 entity belongs is an in-scope MNE group for the fiscal year (a fiscal year that is beginning on or after 1 January 2025) corresponding to the applicable year of assessment; or
-The MNE group to which the Pillar 2 entity belongs was an in-scope MNE group for a fiscal year (a fiscal year that is beginning on or after 1 January 2025) that is preceding the fiscal year corresponding to the applicable year of assessment.
For detailed information on the application of the GloBE Rules in Hong Kong, based on the latest Law, see our:
Hong Kong: GloBE Country Guide
OECD Administrative Guidance: Domestic Implementation Matrix
Transitional CbCR Safe Harbour: Domestic Implementation Matrix
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