On 2 February 2018, the Inland Revenue Department published a law in the official gazette outlining the legal framework for Hong Kong to join a multilateral tax agreement on implementing automatic exchange of information in tax matters (AEOI), automatic exchange of CbC reports of multinational entities, and spontaneous exchange of information on tax rulings.

The new law would enable Hong Kong to implement the AEOI and fulfill its commitments under the OECD / G20 base erosion and profit shifting (BEPS) package. The government said it would prefer to implement these measures through the Multilateral Convention on Mutual Administrative Assistance in Tax Matters rather than continuing bilaterally.