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Hong Kong, the Pillar Two top-up tax notification

In 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, the deadline is **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):

FY2025 Notification:

December Year-end Groups: 30 June 2026
March Year-end Groups: 30 September 2026

FY2026 Notification:

December Year-end Groups: 30 June 2027
March Year-end Groups: 30 September 2027

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.

Note: For fiscal years beginning on or after 1 January 2025, in-scope MNE groups (generally those with annual consolidated revenue of €750 million or more) must comply with these requirements.