Hong Kong: Proposed incorporation of MLI into domestic law

A revenue order incorporating into Hong Kong’s domestic law the MLI

A revenue order incorporating into Hong Kong’s domestic law the MLI

A revenue order incorporating into Hong Kong’s domestic law the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI)—along with the notifications and reservations under the MLI applicable to Hong Kong—was recently published in the gazette.

The order will be introduced into the Legislative Council for negative vetting on 19 October 2022. Subject to completion of the negative vetting procedure, the order will become effective 9 December 2022. However, the exact date the MLI will enter into effect for Hong Kong is still unknown. The earliest possible effective dates of the MLI for Hong Kong are 1 April 2023 (for taxes withheld at source) or 1 April 2024 (for other taxes). 

For a discussion of the modifications to Hong Kong’s existing income tax treaties under the MLI, read TaxNewsFlash

For more information, contact a KPMG tax professional:

David Ling | davidxling@kpmg.com

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