This update is particularly significant for Hong Kong’s minimum tax framework, as mandatory e-filing will apply to years of assessment starting on or after 1 April 2025.
Hong Kong’s Inland Revenue Department has released updated guidelines on the Global Minimum Tax and Hong Kong’s Minimum Top-up Tax for multinational enterprise (MNE) groups on 17 October 2025. These guidelines include new illustrative examples related to the mandatory electronic filing (e-filing) of profits tax returns.
This update is particularly significant for Hong Kong’s minimum tax framework, as mandatory e-filing will apply to years of assessment starting on or after 1 April 2025 (covering the 2025/26 assessment year onwards). The requirement targets MNE groups with annual consolidated revenue of EUR 750 million or more in at least two of the four fiscal years immediately preceding the current fiscal year. These entities fall within the scope of the minimum tax rules, aligning with global tax compliance standards.
Once-in, always-in” mechanism
The mandatory e-filing requirement adopts the “once-in, always-in” mechanism. If a phase 1 applicable entity is mandated to e-file its profits tax return for a year of assessment, the entity will be mandated to e-file its profits tax return for every subsequent year of assessment. This is irrespective of whether or not the entity meets the two conditions as specified above for any subsequent year of assessment. This mechanism will generally apply to those phase 1 applicable entities that subsequently leave an in-scope MNE group, as well as to those entities whose MNE groups subsequently become out of scope.
