Hong Kong Takes a Major Step on Global Minimum Tax, Signing GloBE Information Exchange Agreement

Hong Kong's implementation of the OECD's global minimum tax — known as Pillar Two — reached a significant milestone in May 2026 when the territory signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports relating to GloBE Information.

This signing, confirmed on 11 May 2026, is the latest in a series of steps bringing Hong Kong into full alignment with the 15% global minimum effective tax rate for large multinational enterprise (MNE) groups.

A Three-Year Journey to Compliance

Hong Kong's Pillar Two path has been methodical. After an initial public consultation in December 2023, the government published draft legislation in December 2024, and the Legislative Council formally passed the Global Minimum Tax and Hong Kong Minimum Top-up Tax (HKMTT) legislation in May 2025. In January 2026, Hong Kong obtained "qualified status" under the OECD's Pillar Two framework, confirming its domestic rules meet international standards.

The HKMTT applies to MNE groups with annual consolidated revenue of at least EUR 750 million. Where a group's effective tax rate in Hong Kong falls below 15%, the HKMTT imposes a top-up tax to bring it to the minimum. Similarly, the Income Inclusion Rule (IIR) allows Hong Kong to collect top-up tax on low-taxed foreign profits of Hong Kong-headquartered groups.

What the GloBE Agreement Means

The newly signed information exchange agreement enables Hong Kong's Inland Revenue Department to automatically exchange GloBE-related tax information with partner jurisdictions. This is critical for the global Pillar Two architecture: it allows different countries to verify and reconcile top-up tax calculations, reducing the risk of double taxation and ensuring each jurisdiction collects its fair share.

For businesses, the practical implications are that Hong Kong's tax authorities now have the legal and technical infrastructure to participate in the multilateral exchange of Pillar Two data. MNEs operating in Hong Kong should ensure their country-by-country reporting and GloBE information returns are prepared to the required standard, as they will be shared across borders.

What Comes Next

The IRD is expected to issue detailed filing guidance and templates in the coming months. In-scope MNEs should review their effective tax rate in Hong Kong, assess whether the HKMTT creates a top-up liability, and prepare for the first filing obligations — the first financial year covered will depend on the group's accounting period and the transitional rules adopted by Hong Kong.

Hong Kong is not alone: Singapore, Japan, South Korea, and most EU member states are implementing Pillar Two in parallel. Hong Kong's adherence to the GloBE information exchange framework ensures it remains a cooperative jurisdiction and does not become a target for undertaxed profits rules applied by other countries.

Conclusion

The GloBE agreement signing confirms that Pillar Two is no longer a theoretical discussion for Hong Kong — it is operational reality. MNEs with a Hong Kong presence should treat this as a trigger to move from monitoring to active preparation.

Sources: Deloitte Hong Kong Tax Newsflash Issue 265 (11 May 2026); OECD Pillar Two model rules; IRD.