Updates: Global Minimum Tax and Hong Kong Minimum Top-up Tax for Multinational Enterprise Groups

Tuesday, 25 November 2025

The Inland Revenue Department (IRD) of Hong Kong is implementing key changes related to the Global Minimum Tax and Hong Kong Minimum Top-up Tax for Multinational Enterprise (MNE) Groups.

These changes require in-scope MNE groups, HK standalone JVs, and JV groups to register for unique group codes via Form IR1485. Early application is encouraged for tax administration purposes.

Additionally, the IRD is developing a Pillar Two Portal, an extension of the Business Tax Portal (BTP), to facilitate electronic submissions of top-up tax notifications and returns by Part 4AA entities.

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