Hong Kong SAR

New legislation enacted

The following pieces of legislation were enacted in the past 12 months:

• The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 was gazetted on 6 June 2025 to implement the global anti-base erosion (GloBE) rules (comprising the income inclusion rule [IIR] and the undertaxed profits rule [UTPR]) under Pillar Two of BEPS 2.0 and the Hong Kong minimum top-up tax (HKMTT). The IIR and the HKMTT took effect for a fiscal year beginning on or after 1 January 2025, while the UTPR would take effect on a date to be specified by notice published in the Gazette.
• The Companies (Amendment) (No. 2) Ordinance 2025 was gazetted on 23 May 2025 to introduce an inward company re-domiciliation regime in Hong Kong which came into operation on 23 May 2025.
• The Stamp Duty (Amendment) Ordinance 2025 was gazetted on 16 May 2025 to adjust the ad valorem stamp duty chargeable on a conveyance on sale or an agreement for sale of an immovable property, which took retrospective effect from 11 am on 26 February 2025.
• The Inland Revenue (Amendment) (Tax Concessions) Ordinance 2025 was gazetted on 9 May 2025 to give effect to the 100% reduction of profits tax for the year of assessment 2024/25, subject to a cap of HKD 1,500 Hong Kong dollars (HKD).
• The Inland Revenue (Amendment) (Tax Deductions for Leased Premises Reinstatement and Allowances for Buildings and Structures) Ordinance 2024 was gazetted on 27 December 2024 to give effect to two enhancement measures, namely (i) providing a new profits tax deduction for reinstatement costs for leased premises and (ii) removing the time limit for claiming annual allowances in respect of a commercial/industrial building or structure. These measures took effect from the year of assessment 2024/25.

• The Stamp Duty Legislation (Miscellaneous Amendments) Ordinance 2024 was gazetted on 20 December 2024 to (i) waive the stamp duty payable in respect of the transfer of real estate investment trust (REIT) shares or units and jobbing business of options market makers and (ii) adjust the stamp duty collection arrangement involving approved securities registrars under the uncertificated securities market regime. The Amendment Ordinance relating to the stamp duty waiver came into operation on 21 December 2024.

• The Rating (Amendment) Ordinance 2024 was gazetted on 1 November 2024 to implement a progressive rating system for domestic tenements with rateable value over HKD 550,000. The new system took effect from the fourth quarter of the financial year 2024/25, i.e. January to March 2025.

• The Inland Revenue (Amendment) (Tax Concessions for Intellectual Property Income) Ordinance 2024 was gazetted on 5 July 2024 to establish a patent box regime in Hong Kong, which took retrospective effect from the year of assessment 2023/24.