Pillar Two Portal is a system designated by the Commissioner of Inland Revenue under Part 4AA of the Inland Revenue Ordinance (Cap. 112) ("the Ordinance") for Part 4AA entities to submit top-up tax notifications, file top-up tax returns to the Inland Revenue Department ("the Department"), and view and/or download top-up tax assessments issued by the Department. The Pillar Two Portal is an extended part of the Business Tax Portal (“BTP”). After registration with BTP, Part 4AA entities can access the Pillar Two Portal directly from the BTP.

Separate registration for a Pillar Two Account is not required. Business Tax Portal ("BTP") Administrators of the Part 4AA entity / Authorized Users who are assigned to handle Pillar Two Matters on behalf of the Part 4AA entity can access the Pillar Two Portal directly from the BTP.

For User Guides and e-Demos about the access of Pillar Two Portal from the BTP, please visit the Pillar Two Portal Resource Centre Page.

Yes. A Part 4AA entity can engage a service provider to handle all matters under the Pillar Two Portal through the Business Tax Portal (“BTP”) and should notify the Department of such engagement when the Part 4AA entity sets up or updates its profile of the BTP Business Account. The designated service provider can engage the client under the Tax Representative Portal and access the Pillar Two Portal directly.

You have to register for a Tax Representative Portal (“TRP”) Business Account. Before registering for a TRP Business Account, you must have a registered Business Tax Portal (“BTP”) Business Account with BTP Administrator(s) appointed. After registration with TRP, you can engage the client for handling Pillar Two matters and access the Pillar Two Portal directly.

For User Guides and e-Demos about the access of Pillar Two Portal from the BTP, please visit the Pillar Two Portal Resource Centre Page.

First of all, the Part 4AA entity should provide details of its PRM through the Business Tax Portal ("BTP") when the Part 4AA entity sets up or updates its profile of the BTP Business Account.
For an individual PRM, you can access the Pillar Two Portal through the Part 4AA entity’s BTP Business Account directly. For a corporate PRM, please refer FAQ 4 above.

Yes, please visit the Pillar Two Portal Resource Centre Page for the User Guides and e-Demos.

To register a Business Account under Business Tax Portal ("BTP"), the responsible person performing the registration is required to input, among others, the BRN of the Part 4AA entity. In general, a Part 4AA entity should have a BRN if it carries on business in Hong Kong. If the Part 4AA entity currently does not have a BRN but has the obligations to apply for a business registration certificate, it should approach the Business Registration Office of the Department directly to complete business registration procedures before performing any online registration of the BTP Business Account. If the Part 4AA entity is not carrying on any business in Hong Kong but wishes to register a BTP Business Account to fulfill its reporting obligations, it should write to IRD via beps2.0@ird.gov.hk to request for a Business Registration Number Equivalent ("BRNE"), which will serve the function of the BRN for the purpose of registration with the BTP, by providing the following information:

• the reason why the Part 4AA entity is not required to apply for a business registration certificate in Hong Kong;
• name and Hong Kong Identity Card Number of the responsible person of the Part 4AA entity; and
• whether the Part 4AA entity is a corporation or not.

Yes. Part 4AA entity can authorize a tax representative to handle Pillar Two matters through the Business Tax Portal (“BTP”) and notify the Department of such authorization when the Part 4AA entity sets up or updates its profile of the BTP Business Account. The designated tax representative can, through the Tax Representative Portal (“TRP”), make enquiries relating to Pillar Two matters, and lodge objections against top-up tax assessments on behalf of the Part 4AA entity. Please also refer to FAQ 9 below.

A tax representative, if not engaged as a service provider of the Part 4AA Entity under section 13 of Schedule 63 to the Ordinance, is not allowed to file a top-up tax notification/top-up tax return on behalf of its client. However, the tax representative can view the top-up tax notification/top-up tax return already filed under the Pillar Two Portal, make enquiries and lodge objections against top-up tax assessments under the Tax Representative Portal.

For conducting transactions under the Pillar Two Portal, such as submission of a top-up tax notification and filing of a top-up tax return, the Part 4AA entity, service provider or person managing the non-corporate Part 4AA entity is required to use an e-Cert (Organisational) with AEOI Functions for authentication. For more information about e-Cert (Organisational) with AEOI Functions, please click here to visit the website of the Hongkong Post Certification Authority.

No. An e-Cert (Organisational) with AEOI Functions must be used. The e-Cert (Personal) cannot be used for authentication under the Pillar Two Portal for the Part 4AA entity. Each authorized person, when conducting transactions under the Pillar Two Portal, must hold the relevant organisation’s e-Cert (Organisational) with AEOI Functions issued by the Hongkong Post Certification Authority.

No. An e-Cert (Organisational) with AEOI Functions must be used. An e-Cert (Organisational) is not accepted by the Pillar Two Portal for authentication. The Part 4AA entity may choose to add the new feature of AEOI functions when renewing the existing certificate. For further details of the procedures and documents required, please click here to visit the website of the Hongkong Post Certification Authority.

Yes. The Part 4AA entity can use the same e-Cert (Organisational) with AEOI Functions for authentication under the Pillar Two Portal. It is not required to apply for another digital certificate.

In case you forgot your password, you are recommended to revoke your e-Cert (Organisational) with AEOI Functions immediately and apply for a new one. For more details, please contact the Hongkong Post Certification Authority direct.

A Part 4AA entity of an in-scope MNE group for a fiscal year is required to file top-up tax notifications for that year. As defined in section 1(1) of Schedule 63 to the Inland Revenue Ordinance (Cap. 112), a Part 4AA entity, in relation to an MNE group, means ─
(a)  a HK constituent entities;
(b)  a HK standalone JVs;
(c)  a HK member of a JV group; or 
(d)  a Part 4AA stateless constituent entities.

Yes. If a HK constituent entity ("HKCE") has filed a top-up tax notification in respect of an in-scope MNE group for a fiscal year and identified itself as the ultimate parent entity, the designated filing entity, or the designated local entity of the group, other HKCEs of the group are not required to file top-up tax notifications for that year. Similarly, if a HK member of a JV group has filed a top-up tax notification in respect of a JV group for a fiscal year and identified itself as the designated local entity of the JV group of the in-scope MNE group, other HK members of the JV group are not required to file top-up tax notifications in respect of the same JV group of the MNE group for that year.
However, a HK standalone JV and a Part 4AA stateless constituent entity must file its own top-up tax notification.

Yes.  A top-up tax notification should be filed in respect of each MNE group.

The top-up tax notification should be filed through the Pillar Two Portal.  For details, please refer to A Guide to Submit Top-up Tax Notification. 

Please input “NOTIN” in Item 4(b)(iii) under Part 2 and / or Item 2(c) under Part 3 of Form IR1485.

“NOTIN” should be inputted as “Business Registration Number / Tax Identification Number of the Ultimate Parent Entity” and / or “Business Registration Number / Tax Identification Number of the Joint Venture”.

In completing a top-up tax notification on the Pillar Two Portal, the Notifying Entity can provide details of all HK constituent entities or all HK members of the JV group by either online input or upload a CSV file. The CSV file should be prepared in advance, containing business registration numbers of the entities, and should be saved in UTF-8 ".csv" format.  The system will reject the CSV file, which is not UTF-8 encoded.  For details, please refer to A Guide to Submit Top-up Tax Notification.

i.   the list of Hong Kong constituent entities of the MNE group; or
ii.  the list of Hong Kong members of the JV group.

For accessing the Pillar Two Portal, you need to use web browsers with Internet connection. Current versions of major browsers, namely Firefox, Edge, Chrome and Safari are acceptable. The browser settings must be set in the following manner:
(1)   JavaScript enabled;
(2)   Session cookies enabled.