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In-scope multinational enterprise (“MNE”) groups should register a Business Tax Portal (“BTP”) Business Account for their Hong Kong nominated entity as soon as possible.
The BTP Business Account is required to complete the top-up tax notification obligation, regardless of whether a tax service provider has been appointed to handle tax reporting matters in Hong Kong. Without a BTP Business Account, Hong Kong entities will not be able to complete the top-up tax notification filing.
For broader compliance readiness, MNE groups should also consider setting up BTP Business Accounts for all Hong Kong group entities, as entities of in-scope MNE groups will be subject to mandatory profits tax e-filing from the year of assessment 2025/26 onwards.
What is a BTP Business Account?
Hong Kong Pillar Two compliance applies to MNE groups with annual consolidated revenue of EUR 750 million or above in at least two of the four fiscal years immediately preceding the current fiscal year, for fiscal years beginning on or after 1 January 2025.
These MNE groups are required to comply with Hong Kong’s Pillar Two filings and electronic filings for profits tax returns. A BTP Business Account is therefore necessary to facilitate these reporting obligations.
Why is a BTP Business Account Important?
The BTP Business Account is a prerequisite for Hong Kong Pillar Two compliance and electronic filing of profits tax returns.
If a Hong Kong entity has not yet created its BTP Business Account, including setting up user access and administrator arrangements, the group may face avoidable administrative delays as filing deadlines approach.
Only the Responsible Person (“RP”) of the business can register and create a BTP Business Account. For a corporate entity, the initial setup must be handled by a natural person director or company secretary.
After the BTP Business Account is created, the RP can appoint BTP Administrators, who will be responsible for managing the account and appointing of BTP Authorised Users going forward. Each BTP Business Account can have up to five BTP Administrators, while the number of BTP Authorised Users is unlimited.
Before setting up the BTP Business Account, the RP is required to set up his or her Individual Tax Portal (“ITP”) account. The appointment of the RP should therefore be carefully considered, as this individual will hold the highest level of administrator rights.
ITP Access: Preparing for BTP Business Account Setup
Obtaining access to the ITP may take time. Where the RP already has ITP/eTAX access, iAM Smart or a recognised digital certificate, the access process may be more straightforward. However, if the RP is a non-Hong Kong based director who does not already have the required access, additional processing time should be expected.
| Responsible Person | Access Requirement |
| Hong Kong director Requires eTAX access, iAM Smart or a recognised digital certificate. | Non-Hong Kong director Requires an Access Code from the tax authority for ITP setup and passport-based authentication. Additional processing time should be expected. |
When should the BTP Business Account be Set Up?
The BTP Business Account should be set up in advance to prepare for Pillar Two filings and electronic filings for profits tax returns. The statutory filing due date will depend on the fiscal year-end date of the entity.
| Common Hong Kong Grouping | Example Fiscal Year-End | Top-up Tax Notification Deadline (within 6 months after year-end for fiscal years beginning on or after 1 January 2025) | E-filing Deadline (varies depending on fiscal year-end) |
| D-code group (Accounting Date between 1 to 31 December) | 31 December 2025 | 30 June 2026 | 17 September 2026 |
| M-code group (Accounting Date between 1 January to 31 March) | 31 March 2026 | 30 September 2026 | 16 December 2026 (for profit cases) 1 February 2027 (for loss cases) |
| N-code group (Accounting Date between 1 April to 30 November) | 30 June 2026 | 31 December 2026 | 4 June 2027 |
BTP Readiness Workflow
Group-Level Readiness View
| 1. Relevant Hong Kong notifying entity | --> | Required for top-up tax notification filing |
| 2. Other Hong Kong group entities | --> | Required for mandatory profits tax e-filing and portal-based tax administration |
What Businesses Should Consider Now
- Businesses should consider the following next steps:
- Assess whether the group falls within the scope of Hong Kong Pillar Two.
- Identify the relevant Hong Kong notifying entity for the top-up tax notification.
- Identify the RP for the initial BTP Business Account setup.
- Check whether the RP has ITP/authentication access, or whether additional authentication steps are required before the BTP setup can proceed.
- Create BTP Business Accounts for the required entities to facilitate Pillar Two filings and profits tax return filings.
- Configure the BTP Business Account, including appointing BTP Administrators
With Hong Kong moving towards mandatory electronic filing, setting up a BTP Business Account is essential for both top-up tax filing under Pillar Two and e-filing of profits tax returns. Taking early action can help avoid administrative delays and support compliance with the new requirements.
