GIR XML Schema and User Guides for GloBE Information Return (GIR)

On 08 Jun 2026, the IRD announced that the first phase of the Pillar Two Portal had been launched on 19 January 2026. A Part 4AA entity of an in-scope MNE group for a fiscal year beginning on or after 1 January 2025 can now file a top-up tax notification electronically through the Pillar Two Portal. The second phase will be launched in the fourth quarter of 2026 to accommodate the filing of top-up tax returns, as well as the viewing and downloading of notices of top-up tax assessments by Part 4AA entities.

Legislative Framework and Pillar Two Rules

In July 2021, Hong Kong joined more than 130 jurisdictions in accepting the OECD BEPS 2.0 framework. The Financial Secretary announced in the 2024-25 Budget that Hong Kong would implement the global minimum tax and HKMTT from 2025 onwards. The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 was enacted on 6 June 2025. Under Pillar Two, a global minimum tax of 15% is imposed on MNE groups with annual consolidated revenue of EUR 750 million or above. The rules include the Income Inclusion Rule ("IIR") and Undertaxed Profits Rule ("UTPR"). A jurisdiction with its own QDMTT has priority to collect top-up tax. Part 4AA and Schedules 61 to 64 were added to the IRO. The OECD GloBE rules documents are required to be given effect to supplement the GloBE Model Rules. Hong Kong obtained transitional qualified status for its IIR, HKMTT and QDMTT Safe Harbour from 1 January 2025.

Entity Definitions and Resident Status

A definition of “Hong Kong resident entity” is introduced. An entity is a tax resident in Hong Kong if: where an entity is a company – the entity is incorporated in Hong Kong or, if incorporated outside Hong Kong, normally managed or controlled in Hong Kong; or in any other case – the entity is constituted under the laws of Hong Kong or, if otherwise constituted, normally managed or controlled in Hong Kong. The above definition takes retrospective effect from 1 January 2024. The meaning of constituent entity, joint venture, JV subsidiary, stateless constituent entity and stateless permanent establishment should be read with the definitions as provided in the GloBE Model Rules. The meaning of Part 4AA entity refers to: Hong Kong constituent entity: A constituent entity that is located in Hong Kong; Hong Kong standalone JV: A joint venture that has no JV subsidiary and is located in Hong Kong; A stateless standalone joint venture that is created in Hong Kong; or A stateless standalone joint venture that is a stateless permanent establishment in Hong Kong; HK member of a JV group: A joint venture or its JV subsidiary that is located in Hong Kong; A stateless joint venture or stateless JV subsidiary that is created in Hong Kong; or A stateless joint venture or stateless JV subsidiary that is a stateless permanent establishment in Hong Kong; Part 4AA stateless constituent entity: A stateless constituent entity that is created in Hong Kong; or A stateless constituent entity that is a stateless permanent establishment in Hong Kong.

Filing Deadlines and E-Filing Requirements

Filing deadlines: top-up tax return no later than 15 months after the last day of the reporting fiscal year (18 months for first transition year). Top-up tax notification within six months. Payment due date is one month after expiry of return filing deadline. Objection period is two months. Mandatory e-filing of profits tax returns applies to entities of in-scope MNE groups for a year of assessment beginning on or after 1 April 2025. The “once-in, always-in” mechanism applies. Exceptions include: (1) The entity is being wound-up pursuant to the Companies (Winding Up and Miscellaneous Provisions) Ordinance (Cap. 32) or is being amalgamated pursuant to the Companies Ordinance (Cap. 622); (2) The entity has no record in Business Register; (3) The entity has notified Companies Registry or Business Registration Office of its date of cessation; (4) The accounting period of the entity’s financial statement to be submitted with the profits tax return exceeds 12 months; (5) The profits tax return, where: (i) the return is for the year of assessment 2025/26 and issued on or before 31 March 2026; or (ii) the return is for the year of assessment 2026/27 and issued on or before 31 March 2027; or (6) The submission is re-filing of the profits tax return which had been previously e-filed but subsequently found invalid.

Group Code and Information Reporting

A unique group code will be assigned to each in-scope MNE group, HK standalone JV or JV group. To obtain a group code, an “Application for Group Code in respect of Multinational Enterprise Group, HK Standalone JV or JV Group” (Form IR1485) should be submitted to the Department in paper form. On 21 April 2026, Hong Kong signed the GIR MCAA. This helps minimise compliance burden of in-scope MNE groups as such group filing, together with the dissemination approach as effected through the GIR MCAA, reduces the number of jurisdictions with which these MNE groups must file the GIR.

Reference Materials and Anti-Avoidance

The OECD materials relating to the GloBE Model Rules are listed below for reference: GloBE Model Rules, Commentary to the GloBE Model Rules, Administrative Guidances on the GloBE Model Rules, Illustrative Examples on the GloBE Model Rules, GloBE Information Return, Central Record of Legislation with Transitional Qualified Status. To maintain the integrity of the GloBE and HKMTT regimes, section 61A of the IRO applies, with modifications, to the GloBE and HKMTT regimes as the general anti-avoidance rule ("GAAR"). Under the existing mechanism, section 61A of the IRO may apply to a taxpayer if the following three prerequisites are satisfied: a transaction has been entered into; such transaction has, or would have had but for section 61A, the effect of conferring a tax benefit on the taxpayer; and having regard to the seven matters enumerated in section 61A(1)(a) to (g), it would be concluded that the transaction was entered into or carried out for the sole or dominant purpose of enabling the taxpayer to obtain a tax benefit.