Implementation of Global Tax Rules in Hong Kong

On December 21, 2023, Hong Kong’s FSTB and IRD released a consultation paper on adopting the Global Anti-base Erosion Model Rules (GloBE Rules) and the Hong Kong minimum top-up tax (HKMTT) to address international tax reform. The proposal targets multinational enterprises (MNEs) with annual revenue over EUR750 million, aiming for a minimum 15% tax on profits in each jurisdiction. The plan is to align with OECD guidelines starting in 2025, with HKMTT serving as a Qualified Domestic Minimum Top-up Tax. Key points include the definition of Hong Kong resident entities, HKMTT design mirroring GloBE Rules, and transitional safe harbors for compliance relief. Filing obligations require electronic submission of top-up tax returns and notifications. Overall, Hong Kong seeks to ensure tax fairness and transparency for MNEs.

Full document you can find via this link.

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