Hong Kong Tax News Flash

Jan 2024, Issue 1

Consultation on implementation of global minimum tax and Hong Kong minimum top-up tax launched

As foreshadowed in the 2023-24 Budget announced in February 2023, Hong Kong will implement the 15% global minimum tax on in-scope multinational enterprise (MNE) groups and the domestic minimum top-up tax (DMTT) in Hong Kong (HKMTT) starting from 2025 onwards.

On 21 December 2023, the Government published its much-anticipated consultation paper on the implementation of the global minimum tax and the HKMTT in Hong Kong (Consultation Paper)1. The consultation is open until 20 March 2024, with the expectation that draft legislation will be published in the second half of 2024.

The proposed legislative framework for the global minimum tax and the HKMTT closely follows the global anti-base erosion (GloBE) rules promulgated by the Organisation for Economic Co-operation and Development (OECD). It is proposed that the global minimum tax and the HKMTT will take effect for a fiscal year beginning on or after 1 January 2025.

This news flash summarises the key features of the proposed global minimum tax and HKMTT as well as our observations.

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Charles Lee

Managing Partner - Tax, PwC China

Tel: +[852] 2289 8899

Jeremy Ngai

China South Tax Leader, PwC Hong Kong

Tel: +[852] 2289 5616

Jeremy Choi

Partner, PwC Hong Kong

Tel: +[852] 2289 3608

Rex Ho

Asia Pacific Financial Services Tax Leader, PwC Hong Kong

Tel: +[852] 2289 3026

Cecilia Lee

Partner, PwC Hong Kong

Tel: +[852] 2289 5690

Jenny Tsao

Consumer Markets Tax Leader, PwC Hong Kong

Tel: +[852] 2289 3617

Kenneth Wong

Hong Kong Tax Controversy Services Leader, PwC Hong Kong

Tel: +[852] 2289 3822

Jesse Kavanagh

Hong Kong Tax Reporting & Strategy Leader, PwC Hong Kong

Tel: +[852] 2289 1100

Flora Chan

Partner, PwC Hong Kong

Tel: +[852] 2289 6903

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