Bundle Package: Hong Kong Pillar Two Series - CbCR Safe Harbour and Top-Up Tax

Join us for an insightful webinar series which focused on the Part 1 – transitional CbCR safe harbour calculations, and Part 2 – key adjustment items for detailed top-up tax calculations that may be common to Hong Kong entities if they were not able to pass the Transitional CbCR Safe Harbour.

Overview

The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025, which seeks to implement the Global Minimum Tax (‘GloBE Rules’) and Hong Kong Minimum Top-up Tax (‘HKMTT’) rules in Hong Kong, was enacted on 6 June 2025. The GloBE Rules are intended to ensure that large multinational enterprise groups pay a minimum effective tax rate of 15% on income arising in each jurisdiction where they operate. The GloBE rules consist of Income Inclusion Rule (‘IIR’) as its main rule, and the Undertaxed Profits Rule (‘UTPR’) as the backstop rule. If the effective tax rate (‘ETR’) of a particular jurisdiction is less than 15%, top-up tax would be imposed to bring the ETR of that jurisdiction to 15%. The GloBE rules allows the Qualified Domestic Minimum Top-Up Tax (‘QDMTT’) to apply in priority over the IIR and UTPR to ensure jurisdictions are able to capture top-up taxes arising locally. Calculation of jurisdictional ETR is a complicated process as it would involve various adjustments to the GloBE income and adjusted covered taxes.

In order to minimize the compliance burden of in-scope MNEs, in particular in initial years when the GloBE rules become effective, the OECD has introduced Transitional CbCR Safe Harbour (‘TSH’) such that if a jurisdiction can fulfill one of the three tests to qualify for the TSH, the top-up tax of that jurisdiction shall be deemed to be zero and there is no need to perform full calculations under the GloBE rules for that jurisdiction and hence the compliance burden could be reduced.

Outline
Speakers
Additional information

Remarks: All webinars are conducted in Cantonese.

Part 1 – Transitional CbCR safe harbour calculations l Cantonese l 1 CPD unit

Determine location of an entity
Understand conditions to elect for Transitional CbCR Safe Harbour (‘TSH’)
Understand the three tests under the TSH and where to obtain the relevant data from
Other considerations and best practices

Part 2 – Key adjustment items for detailed top-up tax calculations l Cantonese l 1.5 CPD units

Common adjustment items for GloBE income
Common adjustment items for adjusted covered taxes
Calculation of effective tax rate and allocation of top-up taxes among group entities
Other considerations and best practices

Yiu Hong Chung, Tax Director, International Tax and M&A Services, Deloitte China

Hong is a Tax Director with Deloitte China’s International & M&A Tax Services based in Hong Kong. He is specialised in cross border restructuring and business model optimisation exercises involving China and Hong Kong, including tax free direct and indirect transfers, stamp duty relief, substance enhancement for tax treaty and special regime purposes, etc. Hong is one of the Deloitte China firm’s core members for Pillar 2 services and regularly represented Deloitte Hong Kong in public seminars.

Hong spent one year with International Core of Excellence (ICE) in Deloitte New York office where he provided technical and practical solutions to U.S. based MNCs on their investments, operations and restructuring involving China and Hong Kong. He also worked in Deloitte China's National Technical Centre in Shanghai, where he reviewed and provided comments to draft circulars before official release by the State Taxation Administration of China and contributed to technical writings of the Deloitte China firm.

Hong provides one-stop tax services to multinational and private clients who wish to invest into China and Hong Kong, including structuring and acquisition issues, Pillar 2 advisory, IP planning and implementation, supply chain planning, cross-border transfer pricing strategies, corporate reorganisations, family office set up, and tax/regulatory compliance matters. He has assisted clients in a wide range of industries, including finance, manufacturing, consumer goods, pharmaceuticals, technology, apparel, software and electronics, etc.

Hong holds a B.A. from the Chinese University of Hong Kong. He is a member of the HKICPA.

The two webinars are conducted in Cantonese.
The two webinars are broadcast via ON24.
Each enrolee will receive an email confirmation including the webinar access links and passwords after successful registration.
Enrolee can access the recorded webinars until 31 December 2026.
Enrolee’s own attendance record can be downloaded in the webinar platform after attending each of the webinars.
The series is under ACCA’s Subsidy CPD Scheme. In the Scheme, three percent of seats of our selected CPD events are open on a complimentary and first-come, first-served basis to members who are currently entitled to reduced subscription and retired members on ACCA’s register. ACCA Hong Kong reserves the right to determine which CPD events are included under the Subsidy CPD Scheme. If you are eligible for the Scheme and would like to join the series, please drop us an email to hkinfo@accaglobal.com for enquiries.

Price

Member 215 HKD

Affiliate 215 HKD

Approved employer 320 HKD

Student 215 HKD

Public 430 HKD

Location

Hong Kong SAR of China

Date & time

On demand

Enquiries

Email enquiries hkinfo@accaglobal.com

Book on ACCA

Bundle Package: Hong Kong Pillar Two Series - CbCR Safe Harbour and Top-Up Tax

Overview

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