Hong Kong: Tax Authorities

Hong Kong has introduced the Inland Revenue (Amendment) Bill 2026, significantly expanding tax exemptions for funds and carried interest regimes. The reforms broaden eligible asset classes to include private credit, digital assets, and carbon credits, while streamlining compliance requirements and extending benefits to more investment professionals. These changes complement Hong Kong's broader initiatives to strengthen its position as the world's leading cross-border wealth management centre.

Hong Kong has introduced sweeping reforms to its automatic exchange of information framework, implementing both the OECD's Crypto-Asset Reporting Framework (CARF) and an enhanced Common Reporting Standard (CRS 2.0). These changes mandate registration for all reporting financial institutions, impose stringent due diligence requirements on crypto-asset service providers, and expand tax transparency to cover digital money products and crypto-related investment activities.

Hong Kong's government has proposed significant changes to stamp duty relief rules following court decisions that restricted intra-group transfers. The new legislation aims to expand eligibility beyond traditional share capital structures and lower the ownership threshold from 90% to 75%.

Effective from 10 November 2025, the Hong Kong Inland Revenue Department (IRD) will only issue digital Certificates of Resident Status (CoR) to entities and individuals under the double...

The Hong Kong Inland Revenue Department (IRD) has begun contacting companies potentially affected by the Global Anti-Base Erosion (GloBE) Rules and the newly enacted Hong Kong Minimum Top-Up Tax (HKMTT).

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 operates a territorial tax regime, such that only profits arising in or derived from Hong Kong sources are subject to Profits Tax.

Just over a year has passed since Hong Kong lifted the last COVID-19 measures, but the city is still facing challenges in recovering its economy to pre-COVID levels.

As the new year unfolds, Hong Kong implements two tax rules as of 1 January 2024. The first amendment extends the foreign-sourced income exemption regime ('FSIE Regime') that came into operation on 1 January 2023...