BEPS 2.0: A Fundamental Change to Tax in Hong Kong?

BEPS 2.0: A Fundamental Change to Tax in Hong Kong?

In July 2021, 133 jurisdictions, including Hong Kong, approved a statement providing a framework for the reform of existing international tax rules. Set to take effect in 2023, the new rules propose a global minimum effective tax rate of at least 15% applied on a jurisdiction-by-jurisdiction basis.

Due to Hong Kong’s various incentives and territorial system of taxation, a majority of its companies have an effective tax rate well below 15%. The new rules will apply to groups with turnover in excess of EUR 750 million, although changes to domestic tax rules in response may be more wide-reaching.  Separately, the European Union is conducting a review of foreign source exclusion regimes such as those in Hong Kong, which may also put pressure on Hong Kong’s traditional system of low and simple tax.

In light of the challenges posed for jurisdictions…