On 21 March 2019, the Hong Kong Inland Revenue Department announced a 45-day extension for the submission of the CbC notification in respect of the accounting period beginning 1 January 2018. Under standard rules, the notification for this period would be due by 31 March 2019.
Country-by-Country Reporting – Notification Deadline
Under section 58H of the Inland Revenue Ordinance (Cap. 112), a Hong Kong entity of a reportable group is required to give a notification in relation to country-by-country ("CbC") reporting for an accounting period. The notification must be given electronically via a designated platform, namely the CbC Reporting Portal, within 3 months after the end of the accounting period ("notification deadline"). This requirement applies to an accounting period beginning in or after 2018.
If the first accounting period for which the Hong Kong entity has to give the notification ("first accounting period") begins on 1 January 2018, the relevant notification deadline will be 31 March 2019. However, the Department recognizes that the Hong Kong entity and the service provider engaged by the entity (if any) may need more time to get familiar with the requirements and procedures for giving the notification via the CbC Reporting Portal. Hence for the first accounting period beginning on 1 January 2018, the Department would accept the Hong Kong entity and its service provider as having complied with the time limit prescribed under section 58H, provided that the notification is received via the CbC Reporting Portal on or before the expiry of 45 days after the relevant notification deadline (i.e. 15 May 2019).
Please note that the above treatment only applies to the first accounting period beginning on 1 January 2018. If the first accounting period begins after 1 January 2018, the notification deadline should be duly observed.
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