IRD updated rules on global minimum and top-up taxes, introducing the Pillar 2 Portal and new group registration requirements.
Hong Kong’s Inland Revenue Department released an updated guidance on the global minimum tax and Hong Kong’s minimum top-up tax for multinational enterprise groups on 25 September 2025.
The updates provide clearer instructions for registering eligible groups and submitting notifications and tax returns through the online 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.
A Pillar 2 Portal is being developed to facilitate the submission of the relevant notifications and returns and will be launched in phases from January 2026 onwards. The Pillar 2 Portal is an extended function of the Business Tax Portal (“BTP”).
Part 4AA entities have to register their dedicated business accounts under the BTP for accessing the Pillar 2 Portal directly. The individual authorised to submit top-up tax notifications and top-up tax returns has to use his/her e-cert (Organisational) with AEOI Functions for 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.
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.
