
Hong Kong Pillar Two Filing Guide
A practical guide to Hong Kong’s Registration, top-up tax notification, GIR / top-up tax return architecture, and current Hong Kong-specific data-format rules
Importantly, unlike when determining the revenue for the purposes of the revenue threshold, consolidation adjustments that eliminate intra-group transactions are excluded.
The financial accounting net income or loss is based on the accounting standard used to prepare the consolidated financial statements.
Key Takeaways of the Financial Accounting Net Income or Loss
• There is no reduction in the financial accounting income or loss figure for any minority interest in the constituent entity held by other entities (this is instead taken into account when allocating any top-up tax). For more information, see Allocation of Top-Up Tax.
• Because the financial accounting income or loss figure is based on the profit and loss account, any amounts included in the Other Comprehensive Income section of the financial accounts are generally excluded. Other Comprehensive Income generally consists of items that impact the balance sheet but that aren’t reported in the profit and loss account.
This would include things like unrealized gains or losses on derivatives or retirement benefit plans and foreign currency translation adjustments.
• Although Other Comprehensive Income is generally excluded from the financial accounting income figure, revaluation method gains or losses that are included there are included.
• Consolidated financial accounts will have been prepared based on a materiality threshold. This threshold also applies to the Pillar Two GloBE income calculation.
• If the Constituent Entities’ financial accounts are prepared using an accounting standard different from the Ultimate Parent Entity (UPE) that prepares the consolidated accounts, Article 3.1.3 of the OECD Model Rules provides that another accounting standard may be used if:
o the financial accounts of the constituent entity are maintained based on that accounting standard;
o the information contained in the financial accounts is reliable; and
o permanent differences in excess of EUR 1 million arising from the application to transactions of a particular standard that differs from the UPE’s financial standard, conform to the UPEs accounting standard.

A practical guide to Hong Kong’s Registration, top-up tax notification, GIR / top-up tax return architecture, and current Hong Kong-specific data-format rules

A practical guide to Germany’s Registration, group head notification and GloBE Information Return (GIR) filing through the BZSt framework

Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Amendment (Measures No. 1) Determination 2026, on March 20, 2026. This updates Australia’s domestic lists of foreign Qualified IIRs, foreign Qualified Domestic Minimum Top-up Taxes, and jurisdictions with QDMTT Safe Harbour status

On March 24, 2026, Finland gazetted a law amending its Minimum Tax Act to provide for aspects of the January 2026 OECD Side By Side Tax Package and the June 2024 and January 2025 OECD Administrative Guidance.

On March 24, 2026, Belgium issued an updated draft QDMTT Form and XSD Schema.

A practical guide to Luxembourg’s top-up tax return on MyGuichet.lu, including what the local XML does, which fields drive the filing logic, and where groups usually need extra controls.

On February 27, 2026, South Korea issued an amendment to its international tax adjustment decree to provide for detailed provisions for the application of its QDMTT.

In this article we look at how Japan handles the Pillar Two GloBE Information Return through the e-Tax Multinational Enterprise Information Reporting Corner, what fields Japan localises in the GIR XML and CSV package, and how that sits alongside the Japanese top-up tax return.

View our downloadable checklist for Japan’s Pillar Two filing process.
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