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 fiscal years beginning on or after 1 January 2025, while the UTPR will 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 that 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 1,500 Hong Kong dollars (HKD).