Tax Alert - Implementation of Global Minimum Tax and Hong Kong Minimum Top-Up Tax

Tax Alert - Implementation of Global Minimum Tax and Hong Kong Minimum Top-Up Tax

The HKSAR government has gazetted the draft legislation, the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 (“the Bill”) on 27 December 2024 to implement global minimum tax and a related Hong Kong minimum top-up tax (“HKMTT”) in 2025. 

This tax alert provides an overview of the key aspects of global minimum tax and HKMTT regimes proposed in the Bill, including the charging mechanisms of top-up tax, top-up tax calculation under the HKMTT, safe harbours and the tax compliance requirements for in-scope multi-national enterprise (*MNE”) groups.

As the global minimum tax and HKMTT will take effect in Hong Kong for fiscal years beginning on or after 1 January 2025, in-scope MNE groups should get themselves familiarized with the rules as soon as possible.

For a more in-depth discussion or any specific queries affecting your group’s tax position, we invite you to contact us directly.