HK minimum top-up tax

Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025

• effective from 6 Jun 2025 (except for section 2(11)) 

 

Section 2(11) of the Inland Revenue Ordinance

Section 2(11), amended on 6 Jun 2025, took effect retrospectively on 1 Jan 2024: -

Unless otherwise provided by this Ordinance, an entity is a tax resident in Hong Kong if—

(a) where the entity is a company—the entity is incorporated in Hong Kong or, if incorporated outside Hong Kong, normally managed or controlled in Hong Kong; or

(b) in any other case—the entity is constituted under the laws of Hong Kong or, if otherwise constituted, normally managed or controlled in Hong Kong.

 

Part 4AA - Minimum Tax for Multinational Enterprise Groups

Section 26AD	Interpretation of Part 4AA
Section 26AE	Charge of top-up tax under IIR and UTPR and charge of domestic minimum top-up tax under HKMTT
Section 26AF	Consistency with the OECD GloBE rules documents
Section 26AG	Power to amend definition of OECD GloBE model rules and Schedules 61 to 64

	Sch 61	GloBE Rules
	Sch 62	HKMTT
	Sch 63	Administration of Top-up Taxes
	Sch 64	OECD GloBE Rules Guidance