Pillar Two in Hong Kong (China)
Hong Kong (China) has implemented OECD Pillar Two through Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025. Each applies to fiscal years beginning on or after the respective date: the IIR from 2025-01-01, the QDMTT from 2025-01-01.
Implementation Timeline
Each rule applies to fiscal years beginning on or after the date shown.
Quick reference
| Rule | Effective date | Status |
|---|---|---|
| IIR — Income Inclusion Rule | Fiscal years beginning on or after 2025-01-01 | In force OECD qualified |
| UTPR — Undertaxed Profits Rule | — | Not adopted |
| QDMTT — Qualified Domestic Minimum Top-up Tax Local name: Hong Kong Minimum Top-up Tax (HKMTT) | Fiscal years beginning on or after 2025-01-01 | Newly in force OECD qualified |
| QDMTT Safe Harbour | Available alongside the QDMTT | Case-by-case |
Implementing legislation
- Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 — 2025-06-06 제정. IIR + HKMTT(QDMTT 상당) 일괄 introduction
- UTPR — not yet announced
Practical implications
MNE groups parented in Hong Kong (China) are subject to the IIR for fiscal years beginning on or after 2025-01-01. Where a subsidiary's jurisdictional effective tax rate (ETR) falls below 15%, top-up tax is computed and paid in Hong Kong (China) (as the jurisdiction of the parent entities), and the group must also file the GloBE Information Return (GIR).
MNE groups with constituent entities in Hong Kong (China) are subject to Hong Kong (China)'s QDMTT for fiscal years beginning on or after 2025-01-01. Where the conditions of the QDMTT Safe Harbour are met, the IIR/UTPR computation at the parent jurisdictions may be exempted, reducing the burden of dual computation.
Recent legislative developments
- 2025-06-06: Inland Revenue (Amendment) Ordinance 2025 제정 — IIR + HKMTT 일괄 introduction (2025-01-01 in force)
Related terms
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Open the Architect → Pillar Two AboutSources
- OECD Inclusive Framework — Updated Central Record for Purposes of the Global Minimum Tax, approved 2026-05-11 (current as at 2026-05-01). OECD Global Minimum Tax
- Inland Revenue Department (IRD) — Pillar Two guidance. www.ird.gov.hk
- Hong Kong e-Legislation — Hong Kong legislation database — Inland Revenue (Amendment) Ordinance 2025. www.elegislation.gov.hk
Disclaimer
This page is reference information prepared as of 2026-05-28 by synthesising the primary sources listed above, and is not legal or tax advice. Before applying any of this material in practice, please:
- Verify the latest legislation, administrative guidance, and tax authority notices
- Obtain review by a qualified Pillar Two specialist
- Reassess applicability against the specific facts and circumstances of the group
Translation note. The authoritative version of this page is the Korean original (국가별 현황 › 홍콩). This English version is provided for accessibility and may not capture every nuance of the original sources. Where precision matters, please refer to the Korean original or to the source legislation in its original language.