Under a draft bill, recently published in Hong Kong, on the implementation of global minimum tax and minimum top-up tax, the Income Inclusion Rule and domestic minimum top-up tax will be effective from 1 January 2025, while the Undertaxed Profits Rule will be postponed.A new definition of Hong Kong-resident entity will be introduced with retroactive effect from 1 January 2024; however, it is not expected to affect the tax liability or other obligations under the existing Hong Kong tax system. Executive summaryOn 27 December 2024, Hong Kong published the draft bill1 to implement domestic minimum top-up tax in Hong Kong (HKMTT)...