Hong Kong, the Pillar Two top-up tax notification

Hong Kong, the Pillar Two top-up tax notification for FY2025 must be filed within six months after the end of the fiscal year, specifically by 30 June 2026 for December year-end groups and 30 September 2026 for March year-end groups. This mandatory annual notification is submitted via the Pillar Two Portal (launched Jan 2026) for in-scope Multinational Enterprise (MNE) groups.

Key Pillar Two Notification Deadlines (Hong Kong):

Key Takeaways for Compliance:

• What to File: An annual Top-up Tax Notification must be filed to report, at a minimum, if the MNE is within scope, even if no top-up tax is payable.
• Who Files: Each Hong Kong constituent entity of an in-scope MNE group must notify the Inland Revenue Department (IRD), though a designated entity can file on behalf of others.
• Method: The filing is done electronically via the Pillar Two Portal.
• Consequences: Failure to comply may result in fines of level 3 and further penalties based on undercharged tax.