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Hong Kong Publishes CbC Reporting Guidance including for Voluntary Filing

On 23 December 2016, the Hong Kong Inland Revenue Department (IRD) published guidance on Country-by-Country (CbC) reporting. The guidance covers the general requirements for CbC reporting, which are currently under public consultation. Under the proposed requirements, ultimate parent entities resident in Hong Kong will be required to file a CbC report within 12 months followings its fiscal year-end if its MNE group meets a consolidated group revenue threshold of least EUR 750 million (or HKD 6.8 billion) in the preceding accounting period. In addition, secondary local filing requirements will apply in certain cases where the ultimate parent is not resident in Hong Kong.

One of the main areas further clarified in the guidance is in relation to a transitional arrangement for voluntary parent surrogate filing. Under the transitional arrangement, ultimate parent entities resident in Hong Kong are allowed to voluntarily file a CbC report in Hong Kong for accounting periods commencing between 1 January 2016 and 31 December 2017 (Hong Kong's mandatory CbC reporting requirements to apply from 1 January 2018). Such voluntary filing may relieve a group’s constituent entities in other jurisdictions from a local filing obligation provided that:

  • The required legal framework will have been put in place in Hong Kong by 31 December 2017;
  • Qualifying competent authority agreements will have come into effect between Hong Kong and the tax jurisdictions concerned by 31 December 2017;
  • The IRD has been notified that the CbC reports will be filed by the deadline which is to be provided under the legal framework; and
  • The competent authorities of the tax jurisdictions in which the constituent entities are resident, if required, have been notified that the CbC reports will be filed to the IRD by the deadline prescribed under the domestic legislation of the jurisdictions.

The procedures for voluntary filing in Hong Kong are to be finalized in the first quarter of 2017; but in the meantime, the ultimate parent entity of Hong Kong MNE Group seeking parent surrogate filing in Hong Kong should submit a notification, duly signed by its director, secretary, or responsible officer, to the IRD containing the following information:

  • The name of the ultimate parent entity;
  • The Hong Kong business registration number of the ultimate parent entity;
  • The accounting period(s) for which the group’s CbC report(s) will be filed to the IRD;
  • A list showing the name, tax identification number, and jurisdiction of tax residence (relevant jurisdiction) of each of the constituent entities to be included in the CbC report; and
  • A consent given to the IRD to inform the relevant jurisdictions of the ultimate parent entity's agreement to perform parent surrogate filing in Hong Kong.

The notification should be submitted by post to:

Chief Assessor (Tax Treaty)

G.P.O. Box No. 10856

Hong Kong

(Re: Country-by-Country reporting)  

The notification in the form of electronic record may also be sent by email to

The guidance also notes that the transitional arrangement may not relieve the obligations of group entities in all jurisdictions, as local filing requirements may vary in different jurisdictions.

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