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
Official sources & further reading
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.
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