Under the proposed legislation, while the Income Inclusion Rule (IIR) will take effect in respect of a fiscal year commencing on or after 1 January 2025 and the effective date of the Undertaxed Profits Rule (UTPR) will be deferred to a date to be announced later, the definition of “Hong Kong resident entity” will take retrospective effect from 1 January 2024.
On 27 December 2024, the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 (the Bill) was gazetted. The Bill introduced the global minimum tax and Hong Kong Minimum Top-up Tax (HKMTT) for multinational enterprise (MNE) groups in Hong Kong.
This alert summarizes the key features of the Global Anti-Base Erosion (GloBE) rules and HKMTT and their implementation in Hong Kong.
Clients who have any views on the implementation of the GloBE rules and HKMTT in Hong Kong can contact their tax executives. We will convey the same to the Government in an appropriate manner.