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Insights

CW CPA Professional Insights on China and Cross-Border Business

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Pillar Two Portal Registration: Compliance Requirements for Multinational Groups in Hong Kong

Hong Kong’s Pillar Two Portal enables multinational groups to submit required notifications and top-up tax filings under the global minimum tax regime. This article outlines the portal’s purpose, registration timeline, and practical steps for Hong Kong constituent entities.

Pillar Two Safe Harbours: What They Are, How They Work, and What’s New (2026 Edition)

This article explains the main safe harbour mechanisms under the OECD/G20 Pillar Two global minimum tax framework. It outlines the Transitional CbCR Safe Harbour, the phased increase in Simplified ETR thresholds from 15% to 17%, and the role of the QDMTT Safe Harbour in preventing duplicative top-up taxation. Practical guidance is provided on how multinational enterprises can apply these mechanisms during the early implementation period of the GloBE rules.

A Stronger, More Aligned Hong Kong: Navigating Offshore Claims and FSIE Under a Modernised Global Tax Regime

Hong Kong’s implementation of the Foreign-Sourced Income Exemption (FSIE) regime and the OECD BEPS 2.0 Pillar Two global minimum tax framework has altered the practical value of several traditional tax planning approaches. This article examines how offshore profits claims, the two-tier profits tax rate, and foreign-sourced passive income are treated under the evolving regulatory environment, and what the changes mean for multinational groups and SMEs operating through Hong Kong.

Key Differences Between Singapore and Hong Kong in Implementing BEPS 2.0 Pillar Two

A comparative analysis of how Hong Kong and Singapore are implementing the OECD BEPS 2.0 Pillar Two global minimum tax from 2025. The article examines the HKMTT, Singapore’s DTT and MTT regimes, incentive design, compliance frameworks, and strategic implications for multinational investors operating across Asia.

China’s Updated Foreign Investment Catalogue: Key Changes and Opportunities (Effective February 2026)

China’s 2025 Catalogue of Encouraged Industries for Foreign Investment, effective 1 February 2026, expands the number of encouraged sectors to 1,679 and reflects updated policy priorities in advanced manufacturing, digital infrastructure, and regional development. The revised catalogue introduces new opportunities for foreign investors seeking preferential tax, customs, and regional investment incentives.

Hong Kong Pillar Two Implementation: QDMTT, IIR and Compliance Framework (Effective from 1 January 2025)

Hong Kong implemented the OECD Pillar Two global minimum tax through the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025. This article explains the Hong Kong Minimum Top-Up Tax (HKMTT), the Income Inclusion Rule (IIR), reporting deadlines, and filing obligations for multinational enterprise groups, including how the regime interacts with the OECD GloBE rules and Hong Kong’s existing tax framework.
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