Hong Kong’s Inland Revenue Department updated guidance on the global minimum tax and Hong Kong minimum top-up tax, confirming transitional qualified status for its IIR, HKMTT, and QDMTT Safe Harbour rules, and introducing the Pillar Two Portal and group code registration for in-scope MNEs and joint ventures.
The Hong Kong Inland Revenue Department (IRD) updated its guidance on the global minimum tax and Hong Kong minimum top-up tax for multinational enterprise groups on 8 January 2026. The updates indicate that Hong Kong has received transitional qualified status for its Income Inclusion Rule (IIR), Hong Kong Minimum Top-up Tax (HKMTT), and Qualified Domestic Minimum Top-up Tax (QDMTT) safe-harbour arrangements.
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. A Pillar 2 Portal is being developed to facilitate the submission of the relevant notifications and returns and will be launched by 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.
