The OECD/G20 Base Erosion and Profit Shifting (BEPS) 2.0 project introduces a global minimum tax framework intended to ensure that large multinational enterprise (MNE) groups are subject to a minimum effective tax rate of 15% in each jurisdiction in which they operate.
Hong Kong has implemented the regime through the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025, which adds Part 4AA and Schedules 61 to 64 to the Inland Revenue Ordinance (Cap. 112). These provisions incorporate the OECD Global Anti-Base Erosion (GloBE) rules into Hong Kong law and introduce the Hong Kong Minimum Top-up Tax (HKMTT).
The regime applies to MNE groups with consolidated annual revenue of at least EUR 750 million in at least two of the four fiscal years preceding the current fiscal year. Hong Kong constituent entities of in-scope groups are subject to new reporting and administrative obligations, including electronic filing of Pillar Two notifications and returns through the Inland Revenue Department’s Pillar Two Portal.
What Is the Pillar Two Portal
The Pillar Two Portal is an electronic platform administered by the Inland Revenue Department (IRD) for the submission of filings and notifications required under the minimum tax regime implemented through Part 4AA of the Inland Revenue Ordinance.
The portal enables entities within the scope of the GloBE rules and HKMTT to:
- submit annual top-up tax notifications;
- file top-up tax returns in the prescribed electronic format;
- provide information relevant to the determination of top-up tax liability; and
- receive electronic notices of assessment and other communications relating to Pillar Two administration.
The portal forms part of the broader Business Tax Portal infrastructure used for electronic interaction between taxpayers and the IRD.
Registration Deadlines
- Late 2025: In-scope MNE groups were required to notify the IRD of their obligations.
- January 2026: The Pillar Two Portal officially launched, opening registration for affected groups.
- Ongoing: Each Hong Kong constituent entity of an in-scope MNE group must register promptly to ensure timely filing of notifications and returns.
The IRD has made it clear that late registration may lead to delays in filing and potential non-compliance. For calendar-year taxpayers, the first filings are expected in 2026 for financial year beginning 1 January 2025, making early registration essential.
Challenges MNEs May Face
- Complex Group Structures: Large MNE groups may have multiple Hong Kong constituent entities, requiring coordination to determine which entity will be responsible for portal registration and filings.
- Technical Readiness: The Pillar Two Portal requires electronic submissions and specific filing formats, which may require system adjustments or internal process changes.
- Data Accuracy: Registration requires accurate information on group structure, constituent entities and designated filing entities. Inaccurate information may delay filings or create compliance issues.
- Tight Timelines: With the first reporting cycle expected in 2026 for fiscal years beginning on or after 1 January 2025, portal access and registration should be completed well in advance of the filing deadlines.
Practical Steps
Multinational groups with Hong Kong entities should consider the following preparatory actions:
- Confirm scope: Assess whether the group meets the EUR 750 million consolidated revenue threshold.
- Identify relevant entities: Determine all Hong Kong constituent entities responsible for notification or filing obligations.
- Prepare group information: Compile accurate details of the group structure and designated filing entity.
- Establish portal access: Ensure the relevant entity has an active Business Tax Portal account and the required group code issued by the IRD.
- Plan internal coordination: Confirm which Hong Kong entity will submit notifications or returns on behalf of the group, where applicable.
Conclusion
The introduction of the Pillar Two Portal forms part of Hong Kong’s administrative framework for implementing the global minimum tax regime under Part 4AA of the Inland Revenue Ordinance. The portal serves as the primary electronic channel through which Hong Kong constituent entities of in-scope multinational enterprise groups submit required notifications and returns.
Multinational groups with Hong Kong entities should ensure that portal access, group registration and internal reporting arrangements are established in advance of the first reporting cycle. Early preparation can help minimise filing delays and support timely compliance with the new reporting obligations.
How CW CPA Can Assist
CW CPA supports multinational groups in navigating the administrative and technical requirements associated with Pillar Two Portal registration and ongoing reporting obligations in Hong Kong.
- Scope Assessment: Assessing whether the group meets the EUR 750 million consolidated revenue threshold and falls within the scope of the regime.
- Entity Mapping: Identifying Hong Kong constituent entities and confirming the entities responsible for portal registration and filings.
- Technical Support: Assisting with preparation for electronic filings, including XML or iXBRL reporting requirements where applicable.
- Compliance Coordination: Supporting alignment between Hong Kong portal filings and the group’s global GloBE reporting arrangements.
- Training and Implementation Support: Assisting client teams in establishing internal processes for ongoing use of the Pillar Two Portal.
Multinational groups seeking assistance with Pillar Two Portal registration or compliance preparation may contact CW CPA to discuss their specific reporting and administrative requirements.