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Hong Kong: Reminder of country-by-country notification, reporting requirements

Hong Kong: Reminder of CbC notification

In Hong Kong, the country-by-country (CbC) notification is due by 31 March 2019 for the year ending 31 December 2018.


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The CbC return filing due date is 31 December 2019 for the year ending 31 December 2018.

Multinational enterprise (MNE) groups that have annual consolidated group revenue meeting the threshold amount of HKD 6.8 billion (€750 million) also need to be aware of the following requirements:

  • CbC notification to be filed by at least one Hong Kong company within a reportable group
  • Completion of a new profits tax return (Form BIR51) and supplementary form (Form S2)
  • Rules for filing a CbC return and a CbC report (when applicable)

A CbC notification must be filed by a Hong Kong entity within a reportable group. An MNE group is a reportable group if it had a total consolidated group revenue of at least HKD 6.8 billion for the immediately preceding accounting period when the MNE group’s ultimate parent entity (UPE) is a resident in Hong Kong. For MNE groups with their UPEs being residents outside Hong Kong, the threshold amount refers to the threshold specified by the UPE’s jurisdiction or, in any other situation, is an amount equivalent to the €750 million threshold as of January 2015.

The new Hong Kong profits tax return (Form BIR51) includes new fields to reflect CbC-related items. New supplementary form (Form S2) to the profits tax return relates to transfer pricing and must be completed if the Hong Kong entity belongs to a reportable group. The supplementary Form S2 requires information about whether a CbC notification has been filed; the Hong Kong entity that filed the CbC notification; and details of the group’s UPE. The supplementary form must be submitted with the profits tax return (Form BIR51), and it is not a substitute for completing the (earlier) CbC notification.

The CbC notification and reporting requirements are statutory obligations. Hong Kong companies that are members of MNE groups need to prepare for and understand the information required to comply with their CbC reporting notifications and filing obligations. Accordingly, Hong Kong companies within an MNE group need to determine whether their group’s annual consolidated group revenue exceeds the HKD 6.8 billion threshold and whether a CbC reporting notification must be filed. The determination of the annual consolidated group revenue will initially be for the immediate preceding year (for instance, 2017 for the 2018 year).

Read a January 2019 report prepared by the KPMG member firm in Hong Kong

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