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Hong Kong: Letters to MNE groups potentially in scope of Pillar Two rules

MNEs have two months to reply to letters.

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October 13, 2025

The Inland Revenue Department (IRD) has issued letters to multinational enterprise (MNE) groups in Hong Kong potentially in-scope for the Pillar Two rules, which are applicable to fiscal years beginning on or after January 1, 2025. Read TaxNewsFlash

The IRD requests that each MNE receiving a letter (1) assess whether it belongs to an in-scope MNE group, and (2) return a completed reply slip within two months from the issuance date of the letter.

If the MNE belongs to an in-scope MNE group, the IRD requests additional information to be provided and further actions to be taken.


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

Burcin Nee | bnee@kpmg.com

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