Hong Kong imposes 4 separate filing obligations under Pillar Two. The earliest is Top-up Tax Notification, due within 6 months after the last day of the reporting fiscal year. Checked against the authority on 10 October 2026.
A six-month notification sits well ahead of the return, and the access prerequisites behind it — a business registration number, a group code applied for on paper, and a specific class of digital certificate — are the real lead time.
BTP account + BRN or BRNE + MNE group code (Form IR1485) + e-Cert (Organisational) with AEOI Functions
Three separate prerequisites, each with its own process. An entity with no Business Registration Number must either register a business or email beps2.0@ird.gov.hk for a BRN Equivalent. The group code is applied for on Form IR1485 in PAPER. A standard e-Cert (Organisational) is not accepted — it must carry AEOI Functions; one already used for CbC Reporting can be reused.
| Charge | Local name | In force from |
|---|---|---|
| IIR | Income inclusion rule (IRO Part 4AA) | Fiscal years beginning on or after 1 Jan 2025 |
| UTPR | Adopted but not commenced — start date to be set by Gazette notice | Not yet commenced |
| Domestic | Hong Kong minimum top-up tax (HKMTT) | Fiscal years beginning on or after 1 Jan 2025 |
Also: Schedule 63 s.5(1) notification
Declares the group is in scope, identifies the entity and jurisdiction from which Hong Kong will receive the GIR, and lists the local entities relieved from filing. One Hong Kong entity may file for the group, but Hong Kong standalone JVs and Part 4AA stateless constituent entities must file their own.
Global minimum tax and Hong Kong minimum top-up tax — Inland Revenue Department ↗
Also: Schedule 63 s.3(1) return
The return itself, which the IRD states incorporates the information required in the GIR. Assessed on the declared return, with no provisional tax. Where a designated paying entity defaults, all Hong Kong constituent entities are jointly and severally liable.
Global minimum tax and Hong Kong minimum top-up tax — Inland Revenue Department ↗
Also: GIR · Schedule 63 s.6
Not required from Hong Kong constituent entities where it is filed in a jurisdiction that can exchange it with Hong Kong under a qualifying competent authority agreement. Hong Kong signed the GIR MCAA on 21 April 2026. Filed in XML to the OECD GIR schema with the IRD's supplementary guide; 200MB recommended maximum after compression.
Pillar Two Portal Resource Centre — Inland Revenue Department ↗
Electronic filing of the ordinary profits tax return becomes mandatory for in-scope entities, on a once-in-always-in basis.
Global minimum tax and Hong Kong minimum top-up tax — Inland Revenue Department ↗
IRO s.80O: failure to file the return or notification — level 3 fine plus a further fine of three times the top-up tax undercharged; a misleading, false or inaccurate return or notice attracts the same. Failure to comply with a court compliance order — level 4 fine. s.80P applies level 3 fines to service providers. s.82 wilful evasion: summary conviction level 3 plus three times the undercharged tax and up to 6 months; on indictment level 5 plus three times and up to 3 years. s.82A allows additional tax of up to three times the undercharged amount where no prosecution has been brought on the same facts.
4 separate obligations: Top-up Tax Notification; Top-up Tax Return; GloBE Information Return; Profits tax e-filing (BIR51 / BIR52).
Within 6 months after the last day of the reporting fiscal year. Filed by: Each Part 4AA entity of an in-scope group. Channel: Pillar Two Portal, an extension of the Business Tax Portal; live since 19 January 2026.
15 months after the last day of the reporting fiscal year; 18 months for the first transition year. Payment one month after the later of that date and the assessment notice. Filed by: Each Hong Kong constituent entity, or the designated local entity on their behalf. Channel: Pillar Two Portal phase 2, expected Q4 2026.
BTP account + BRN or BRNE + MNE group code (Form IR1485) + e-Cert (Organisational) with AEOI Functions. Three separate prerequisites, each with its own process. An entity with no Business Registration Number must either register a business or email beps2.0@ird.gov.hk for a BRN Equivalent. The group code is applied for on Form IR1485 in PAPER. A standard e-Cert (Organisational) is not accepted — it must carry AEOI Functions; one already used for CbC Reporting can be reused.
IRO s.80O: failure to file the return or notification — level 3 fine plus a further fine of three times the top-up tax undercharged; a misleading, false or inaccurate return or notice attracts the same. Failure to comply with a court compliance order — level 4 fine. s.80P applies level 3 fines to service providers. s.82 wilful evasion: summary conviction level 3 plus three times the undercharged tax and up to 6 months; on indictment level 5 plus three times and up to 3 years. s.82A allows additional tax of up to three times the undercharged amount where no prosecution has been brought on the same facts.
Every row on this page was checked against the authority's own published page on 10 October 2026. The best-documented jurisdiction in this set. Obligations, deadlines, portal mechanics and prerequisites come from the IRD's own pages; the penalties were read in the Amendment Ordinance itself. Only the standalone GIR deadline is unpublished.
Saurabh Satija, “Hong Kong Pillar Two filing obligations”, https://saurabhsatija.com/pillar-two-hong-kong, accessed [date].
Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.
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This page shows what Hong Kong requires. The scoping tool takes your whole footprint and returns every filing it triggers, in deadline order, with the access prerequisites attached. About thirty seconds.