Hong Kong Tax News Flash
Dec 2024, Issue 21
Bill on implementation of global minimum tax and Hong Kong minimum top-up tax gazetted
As a member of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), Hong Kong is committed to implementing the global anti-base erosion (GloBE) rules under Pillar Two of BEPS 2.0.
Following the consultation outcome published in October 2024, a bill was gazetted on 27 December 2024 to implement the GloBE rules, which comprises the income inclusion rule (IIR) and undertaxed profits rule (UTPR), as well as the Hong Kong minimum top-up tax (HKMTT).
The bill will be introduced into the Legislative Council for first reading on 8 January 2025. Subject to the passage of the bill, the GloBE rules and the HKMTT will take effect as follows:
Aspect |
Effective date |
IIR and HKMTT |
For a fiscal year beginning on or after 1 January 2025 |
UTPR |
To be specified by notice published in the Gazette |
Definition of Hong Kong resident entity |
Retrospectively from 1 January 2024 |
The Inland Revenue Department (IRD) has also published online guidance to explain the bill.
This news flash discusses the key features of the bill and provides our observations thereon.
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