Hong Kong Tax News Flash
May 2025, Issue 8
Global minimum tax and Hong Kong minimum top-up tax bill passed
On 28 May 2025, the bill on the implementation of the global anti-base erosion (GloBE) rules and the Hong Kong minimum top-up tax (HKMTT) (Bill), together with certain amendments to the Bill by way of committee stage amendments (CSAs), was passed by the Legislative Council (LegCo). It is expected that the Bill will be gazetted as an amendment ordinance on 6 June 2025.
Upon gazettal of the amendment ordinance, the GloBE rules (comprising the income inclusion rule (IIR) and the undertaxed profits rule (UTPR)) and the HKMTT will take effect as follows:
| Aspect | Effective date |
| IIR and HKMTT | For a fiscal year beginning on or after 1 January 2025 |
| UTPR | To be specified by notice published in the Gazette |
| Definition of Hong Kong resident entity | Retrospectively from 1 January 2024 |
This news flash summarises the key features of the GloBE and HKMTT legislation as passed by the LegCo.
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