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CMS Expert Guide to Mastering OECD's Pillar Two in Hong Kong

Key stages in the introduction of global minimum taxation

Table of contents
  1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force?
  5.  When will the Undertaxed Payments Rule (UTPR) come into force? 
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?
  7. Further comments
Hong Kong
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1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

22 February 2022: announcement by Hong Kong’s Financial Secretary in his Budget speech regarding Hong Kong’s desire to implement the 15% global minimum effective tax rate in order to preserve its tax rights and maintain its competitiveness. 

3. Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?

No information available.

4. When will the Income Inclusion Rule (IIR) come into force?

2025.

5. When will the Undertaxed Payments Rule (UTPR) come into force? 

2025.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

2025.

7. Further comments

Hong Kong plans to apply the global minimum effective tax rate to large multinational entity (MNE) groups and plans to implement its domestic minimum top-up tax starting from 2025 onwards. 
The government will launch a consultation exercise to allow MNE groups to prepare.