Hong Kong enacts law on BEPS 2.0 Pillar Two

09 June 2025|Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation, Global, BEPS 2.0|Hong Kong

On 6 June 2025, Hong Kong gazetted legislation to implement Pillar Two of the OECD BEPS 2.0 initiative, with the domestic minimum top-up tax (HKMTT) and Income Inclusion Rule (IIR) effective retroactively from 1 January 2025, while the Undertaxed Profits Rule is postponed for further study.
The HKMTT applies to multinational enterprise (MNE) groups with consolidated revenues of €750m or more, affecting all Hong Kong constituent entities regardless of ownership interest, while providing relief to …

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