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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

Hong Kong has a very lenient system of taxation. The rates are low and tax is charged only on income which has a Hong Kong source.

The Mainland and Hong Kong signed an Arrangement between them for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (the "Arrangement") on 21 August 2006 to eliminate any situation of double taxation that might otherwise be faced by a Mainland or Hong Kong investor or resident in the conduct of cross border activities.

With intellectual property playing an ever-increasing role in economic development, the need to harness, promote, and protect ASEAN innovation remains urgent as integration progresses...

The Inland Revenue (Amendment) (No. 2) Bill 2011 (the "Bill") was gazetted on 25 February 2011.

For many foreign nationals Hong Kong is an ideal place to work and accumulate wealth but most choose to retire elsewhere.

The courts have recently handed down two separate tax decisions, both highlighting the need for vigilance from the taxpayer when managing its tax affairs.

On 2 November 2005, the Legislative Council in Hong Kong passed the Revenue (Abolition of Estate Duty) Bill 2005 seeking to amend the Estate Duty Ordinance ("EDO") with a view to abolish estate duty in Hong Kong.

Further to the implementation of the three-tier transfer pricing ("TP") documentation rules in Hong Kong, many multinational enterprises ("MNEs") are working with their TP specialists to fulfil...

需注意，合资格的单一家办和家控工具必须由同一"家族成员"直接或间接拥有至少75%至95%的实益权益.

Companies, wherever they are based, are required to process employee salaries accurately and on time.

The aviation finance industry continues to expand across Asia, driven by booming air travel in China, India and other regional markets, causing a growing number of aircraft lessors to look at setting up operations...

On 21 October 2005, SAFE issued a new circular on "Relevant Issues Concerning Foreign Exchange Control on Domestic Residents' Corporate Financing and Roundtrip Investment Through Offshore Special Purpose Vehicles" ("Circular 75"), effective 1 November 2005.

The Bill was considered by LegCo on 2 November and approved on the same day.

Transfers of HK stock are exempt from HK stamp duty where the transferor & transferee are associated bodies corporate.

The Inland Revenue Department ("IRD") however, has traditionally viewed carried interest as an incentive reward which supplements management fees for the provision of management services.