Hong Kong Tax Authority updated its guidance on January 8, 2026. The update explains that a dedicated Pillar Two e-filing portal will be introduced in phases from January 2026. From the 2025–26 year of assessment, affected groups must file profits tax returns, Hong Kong minimum top-up tax declarations, and related information returns electronically. The guidance also confirms that Hong Kong’s income inclusion rule and domestic top-up tax are treated as qualified rules from January 1, 2025.
To read more on the Guidance, click here.
On June 6, 2025 Hong Kong’s Inland Revenue Department published guidance on implementation of the new 15% global minimum tax in accordance with Ordinance No. 21/2025, in conjunction with the OECD Pillar Two rules. The guidance explains how the rules apply to large multinational groups beginning January 1, including the Hong Kong minimum top-up tax, income inclusion rule, and undertaxed profits rule. The guidance also provides details on how to establish whether an entity is resident in Hong Kong, how the taxes are charged, the safe harbors, filing requirements, and the move to mandatory electronic filing for profits tax returns.
To access the Guidance, click here.
On May 28, 2025 the Hong Kong’s Legislative Council enacted an amendment to the Inland Revenue Bill 2024, introducing a 15% global minimum tax for multinational enterprises. The provision included a domestic top-up tax to apply to companies within Hong Kong making less than the stated minimum rate. This policy highlights Hong Kong’s pledge to international cooperation (tax) and action against tax avoidance.
To read more on the global minimum tax, click here.
Hong Kong’s government announced plans to introduce two global minimum tax rules, with a third rule to follow later. The Minimum Tax for Multinational Enterprise Groups Bill 2024 will bring in the qualified domestic minimum top-up tax (QDMTT) and income inclusion rule starting January 1, 2025. The QDMTT, known as the Hong Kong top-up tax, ensures local companies pay at least 15% tax. The income inclusion rule allows a company’s headquarters to add extra tax on subsidiaries taxed below 15%.
These rules are part of the OECD’s global deal, which includes Pillar One (profit reallocation to customer locations) and Pillar Two (a 15% minimum tax). Another rule, the undertaxed profits rule, will be added later. The bill is expected to raise HKD15 billion annually by 2027-28 and will be read in the Legislative Council on January 8, 2025.