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beps-2-0-implementation-in-hk-diagram

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.


What should you do

  • Estimate the impact
  • Be ready for compliance
  • Manage stakeholders
  • Comply with financial reporting requirements
  • Look for planning opportunity
  • Stay attentive to the developments

How can KPMG help

  • Offer market-leading technology
  • Perform impact assessment
  • Collaborate with our accounting experts
  • Assist in implementing business plans
  • Identify potential mitigating actions
  • Provide timely technical updates

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Contact us


John Timpany

Head of Tax, Hong Kong SAR
KPMG China


Ivor Morris

BEPS 2.0 Project Leader
KPMG China


Stanley Ho

Tax Partner, Hong Kong SAR
KPMG China