Hong Kong: Pillar Two global minimum tax rules receive legislative approval

It is expected that the corresponding Ordinance will be gazetted on June 6, 2025, and become effective on the same date.

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May 29, 2025

The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024) implementing the Pillar Two global minimum tax rules—together with over 100 government proposed amendments to the bill—were passed by the Legislative Council on May 28, 2025. Read TaxNewsFlash

It is expected that the corresponding Ordinance will be gazetted on June 6, 2025, and become effective on the same date. Upon gazettal of the Ordinance, the income inclusion rule (IIR) and Hong Kong minimum top-up tax will take effect retrospectively in the Hong Kong SAR for fiscal years beginning on or after January 1, 2025, whereas the undertaxed profits rule will become effective from a date to be specified by the government at a later stage. 

For more information, contact the Global Leader of KPMG Global Transfer Pricing Services:

Burcin Nee | bnee@kpmg.com

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