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Pillar Two Developments In Hong Kong – The IRD's Letter To In-Scope MNE Groups
Following the enactment of the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 (the Ordinance)1 in June 2025, the Income Inclusion Rule (IIR) under BEPS Pillar Two and Hong Kong Minimum Top-up Tax (HKMTT) take effect retrospectively in the Hong Kong SAR (Hong Kong) for fiscal years beginning on or after 1 January 2025
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