Hong Kong enacts the global minimum tax and HKMTT
The minimum tax ordinance was enacted on 6 June 2025 and applies to large groups from 2025.
- Where
- China ↔ Africa · China ↔ ASEAN · US ↔ Japan · Hong Kong SAR
- Published
- Last reviewed
- Prepared
- Prepared by the Intelligence desk with AI-assisted research from the cited sources, checked on 12 November 2026.
- Effective
- 1 January 2025
- Version
- 1
What changed
The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 was enacted on 6 June 2025. It puts into Hong Kong law the global minimum tax under the OECD's BEPS 2.0 framework and a Hong Kong minimum top-up tax (HKMTT) from 2025 onwards. Where an in-scope group's effective rate in Hong Kong is below 15%, Hong Kong can collect the top-up itself rather than leave it to another jurisdiction.
Who is affected
Multinational groups with consolidated revenue of EUR 750 million or more that have Hong Kong entities, and Hong Kong-parented groups with low-taxed subsidiaries elsewhere.
Why it matters
The two-tier 8.25% / 16.5% rates and the territorial system remain. For large groups, however, the effective rate in Hong Kong is now topped up to 15%. Singapore made the same change from 1 January 2025, so for these groups the comparison between the two now turns more on treaties, substance and operations than on rate.
What to examine next
Check whether the group is in scope and from which fiscal year.
Model the Hong Kong effective rate including any offshore-sourced or exempt income.
Plan the registration and return filings with the Inland Revenue Department.
Use the Singapore vs Hong Kong Decision Map to compare holding locations.
Sources
- Global minimum tax and Hong Kong minimum top-up tax for multinational enterprise groupsInland Revenue Department · checked 12 Nov 2026 · primary source
Next steps, if you need them
Original analysis by the UNBOUNDED Intelligence desk. Linked sources belong to their publishers. This briefing is information, not legal, tax, investment or other professional advice. Its appearance here is not an endorsement by UNBOUNDED or any institution of a transaction, jurisdiction, strategy or counterparty.