Hong Kong has launched the first phase of its Pillar 2 portal, allowing multinational enterprises to file electronic top-up tax notifications as part of the new global minimum tax framework.
The Hong Kong Inland Revenue Department (HKIRD) launched the first phase of its Pillar 2 Portal on 19 January 2026, enabling taxpayers to electronically file top-up tax notifications through the new system.
The Pillar 2 Portal includes user guides and e-demo among other materials.
In July 2021, Hong Kong joined more than 130 jurisdictions in accepting the international tax reform framework of a two-pillar solution announced by the Organisation for Economic Co-operation and Development (OECD) to tackle base erosion and profit shifting risks arising from the digitalisation of the economy (commonly known as BEPS 2.0).
To fulfil Hong Kong’s international obligation to tackle cross-border tax evasion and safeguard our taxing rights, the Financial Secretary announced in the 2024-25 Budget that Hong Kong would implement the global minimum tax in accordance with the BEPS 2.0 framework promulgated by the OECD, and a related Hong Kong minimum top-up tax (HKMTT) from 2025 onwards.
The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 (the Amendment Ordinance) was enacted on 6 June 2025 to give effect to the initiative.
Qualified rule status
The IIR, UTPR and HKMTT, as well as the QDMTT Safe Harbour, in Hong Kong must be implemented in a way which achieves consistent outcomes with the GloBE Model rules and OECD GloBE rules documents such that the relevant qualified rule status can be obtained during the OECD’s peer review process which comprises a full legislative review and ongoing monitoring. This seeks to ensure the effectiveness of the GloBE rules underpinned by the consistent application of the rules across jurisdictions.
The OECD has developed a transitional qualification mechanism for recognition of the qualified status of jurisdictions’ domestic rules on a temporary basis, pending a full legislative review. The OECD’s website maintains a central record for jurisdictions whose minimum tax legislation has secured transitional qualified status under the transitional qualification mechanism.
Hong Kong has obtained transitional qualified status for its IIR, HKMTT and QDMTT Safe Harbour from 1 January 2025, and has been included in the OECD’s central record of legislation with transitional qualified status.
Pillar 2 Portal
A Part 4AA entity of an in-scope MNE group must file a top-up tax notification and a top-up tax return in the form of an electronic record using a system designated by the Commissioner. The first phase of the Pillar 2 Portal has been launched to allow Part 4AA entities to file annual top-up tax notifications relating to their obligations of filing top-up tax returns. The second phase will be launched in the fourth quarter of 2026 to accommodate the filing of top-up tax returns, as well as the viewing and downloading of notices of top-up tax assessments by Part 4AA entities.
Indeed, the Pillar 2 Portal is an extended function of the Business Tax Portal (BTP). The entities which are required to file top-up tax notifications for the MNE groups (notifying entities) have to register their dedicated business accounts under the BTP for accessing the Pillar 2 Portal directly. The notifying entities are required to file top-up tax notifications online through the Pillar 2 Portal within six months after the last day of the fiscal year.
The individuals who are authorised to sign and submit top-up tax notifications and top-up tax returns on behalf of the notifying entities are required to use their e-cert (Organisational) with AEOI Functions for the purposes of authentication. Besides, the electronic notices of top-up tax assessment will be issued to BTP Business Accounts of the relevant filing entities and assessed entities for their viewing and downloading.
A service provider engaged under section 13 of Schedule 63 to the IRO, a tax representative appointed for the purposes of global minimum tax and Hong Kong minimum top-up tax, and a person acting for or managing the non-corporate Part 4AA entity (collectively Service Agent) may access the online services under the Pillar 2 Portal for or on behalf of the Part 4AA entity. The management of Service Agents can be made through the BTP by the BTP Administrator(s).
Registration of in-scope MNE groups via application for group codes
For identification and tax administrative purposes, a unique group code will be assigned to each in-scope MNE group, HK standalone JV or JV group. When accessing a top-up tax notification under the Pillar 2 Portal for completion and filing, a Part 4AA entity will be required to provide the MNE code assigned to the in-scope MNE group. If the entity is a HK standalone JV or a HK member of a JV group of an in-scope MNE group, it will be further required to provide the JV code assigned to the HK standalone JV or JV group.
To obtain a group code, an “Application for Group Code in respect of Multinational Enterprise Group, HK Standalone JV or JV Group” (Form IR1485) should be submitted to the Department in paper form. The relevant Groups are encouraged to apply early for group codes.
