Following the OECD statement (8 October 2021) on the agreement on the core design features of the two-pillar solution developed in the BEPS 2.0 project, the Hong Kong government reiterated its earlier position that it will implement the BEPS 2.0 package based on the BEPS 2.0 model rules to be finalized by the OECD.¹ The two pillars are:

• Pillar One on revisions to nexus and profit allocation rules

• Pi…