What happened?
Hong Kong’s Inland Revenue Department added top-up tax return filing and access to assessment notices to its Pillar Two Portal on 26 October 2026. The functions cover relevant Part 4AA entities for reporting fiscal years beginning on or after 1 January 2025.
Key details
BIR82 must be filed electronically; paper filing is not accepted. A designated local entity may file for the relevant Hong Kong constituent entities, with appointment renewed for each reporting fiscal year. Relief from providing GIR information depends on qualifying overseas filing and information exchange conditions; it is not a blanket exemption from local return obligations.
Effective date / timing
The general return deadline is 15 months after the reporting year ends, extended to 18 months for the first transition year. The separate annual notification is due within six months after year-end. The portal enhancement does not introduce a new tax or restart these periods.
Business impact
Tax & Markets analysis: confirm portal accounts, authorised signatories and annual appointments before filing. Reconcile the local assessment information with the group GIR, including where that GIR is filed abroad. Test the data handover between the group tax team and the Hong Kong filing entity.
Sources
Primary and secondary sources are distinguished below. See our methodology for verification and correction standards.