BEPS 2.0 implementation in Hong Kong (SAR)

With Hong Kong implementing Pillar 2 rules in 2025, why your group needs to act now?

• Some overseas jurisdictions (e.g., Korea, United Kingdom, Ireland, etc) have already implemented Pillar 2 rules in 2024 and your local group entities may be impacted

• With less than 6 months before the implementation, your group needs to understand the impact and establish an action plan as soon as possible

• There are designated rules for special holding structures (e.g., minority shareholding, joint ventures, etc.) and your group’s Pillar 2 work may need to involve other stakeholders

• The past planning (e.g., reduced tax rate, enhanced tax deduction) may no longer be tax efficient and would require a holistic review.