Hong Kong’s Inland Revenue Department issued letters in late September 2025 to MNE groups potentially subject to the global minimum tax rules under Pillar Two to notify them of upcoming Pillar Two compliance obligations. The letter also provides an overview of the income inclusion rule (IIR) and minimum top-up tax (HKMTT) and outlines the relevant support offered by the IRD to MNE groups. Hong Kong’s IIR and HKMTT apply to fiscal years starting in 2025.
The following deadlines apply for calendar year in-scope taxpayers:
A recipient of the IRD letter is required to take the following steps within two months of receipt of the letter:
While the IRD has made efforts to identify all in-scope MNE groups, some groups may have been missed. Groups should coordinate internally to determine whether any entity has received the IRD letter and responded accordingly. If a letter has not been received, the group may wish to proactively contact the IRD or consult their tax advisors. Regardless of receipt, management should be made aware of the upcoming Pillar Two filing obligations and the need for a timely application for the MNE group code/JV code(s).
Carol Lam
BDO in Hong Kong
The following deadlines apply for calendar year in-scope taxpayers:
- November 2025: Deadline to reply to the letter to declare in-scope status and apply for group/JV codes.
- 30 June 2026: Deadline to file the top-up tax notification.
- 30 June 2027: Deadline to file the top-up tax return for the first transition year.
A recipient of the IRD letter is required to take the following steps within two months of receipt of the letter:
- Confirm whether the recipient is part of an in-scope MNE group for the 2025 fiscal year;
- Request an MNE group code and/or JV code(s) to enable the filing of top-up tax notifications and returns;
- Identify the number of Hong Kong group entities that are required to electronically file profits tax returns for the 2025/26 year of assessment; and
- Register for the Business Tax Portal (BTP).
BDO Insight
While the IRD has made efforts to identify all in-scope MNE groups, some groups may have been missed. Groups should coordinate internally to determine whether any entity has received the IRD letter and responded accordingly. If a letter has not been received, the group may wish to proactively contact the IRD or consult their tax advisors. Regardless of receipt, management should be made aware of the upcoming Pillar Two filing obligations and the need for a timely application for the MNE group code/JV code(s).Carol Lam
BDO in Hong Kong