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Hong Kong enacts law on BEPS 2.0 Pillar Two

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Hong Kong

  • On 6 June 2025, Hong Kong gazetted legislation to implement Pillar Two of the OECD BEPS 2.0 initiative, with the domestic minimum top-up tax (HKMTT) and Income Inclusion Rule (IIR) effective retroactively from 1 January 2025, while the Undertaxed Profits Rule is postponed for further study.
  • The HKMTT applies to multinational enterprise (MNE) groups with consolidated revenues of €750m or more, affec…

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