Hong Kong (HK)

Jurisdiction Overview

419 *CBCR: Is there a local filing requirement of a global country-by-country reporting file (according to OECD’s BEPS Action 13) by large corporate groups (with a worldwide turnover higher than 750 million Euro) and local subsidiaries of foreign groups? OECD Legislation: Secondary mechanism is subject to restrictions imposed by OECD model legislation; or no secondary mechanism at all (only the domestic ultimate parent entity has to file the CbCR)
 Data Date: 2019


In 2018, the OECD wrote that Hong Kong was in the process to approve domestic legislation (OECD CBCR 2018: 298). However, the Inland Revenue (Amendment) (No. 6) Ordinance 2018, which commenced operation on 13 July 2018, put in place a legislative framework for Hong Kong to implement the CbC reporting. It requires an international agreement to trigger local filing (www.ird.gov.hk).
According to the OECD, "Hong Kong has introduced local filing requirements in respect of fiscal years beginning on or after 1 January 2018. No inconsistencies were identified with respect to the limitation on local filing obligation" (OECD CBCR 2019: 232).