Jurisdictions › Hong Kong
Enacted

Hong Kong Pillar Two

Asia-Pacific

Effective
Jan 2025
IIR local name
IIR
QDMTT local name
Hong Kong Minimum Top-up Tax (HKMTT)
IIR
IIR
Enacted
UTPR
Not adopted
✕ Not adopted
QDMTT
Hong Kong Minimum Top-up Tax (HKMTT)
Enacted
In development — This profile is provided for reference only and may contain inaccuracies. Always verify against official legislation and current OECD guidance.
Key implementation point

Patent Box (5% rate on IP income) and other preferential regimes create HKMTT exposure for IP-intensive Hong Kong entities.

Implementation detail
  • 01 Hong Kong enacted via Ordinance in 2024, effective 1 January 2025.
  • 02 HKMTT (Hong Kong's QDMTT) tops up to 15% on Hong Kong constituent entities.
  • 03 Hong Kong's standard profits tax rate is 16.5% — above 15% — but preferential regimes can reduce effective rates.
  • 04 Preferential regimes: Patent Box (reduced 5% rate on qualifying IP income), professional reinsurance, captive insurance.
  • 05 IIR enacted but limited impact as most Hong Kong UPEs of large groups are already above 15%.
  • 06 UTPR not enacted.
  • 07 IRD (Inland Revenue Department) issued practice notes on GloBE compliance.
Enacted legislation Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2024
Track Hong Kong rules against your live MNE

In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.

See it in the sandbox →