Under Hong Kong Transfer Pricing Law, a multinational enterprise group (MNE Group) is required to file a CbC Report in relation to an accounting period where:

The deadline for filing a CbC Return is 12 months after the end of the relevant accounting period or the date specified in the assessor’s notice, whichever is the earlier.

A service provider may be engaged to file a CbC Return or the related notification. Penalties are provided in respect of matters such as failing to file CbC Returns and providing misleading, false or inaccurate information in CbC Returns. Some of the penalty provisions will also apply to service providers.

As your service provider, we can assist you to access the CbC Reporting Portal.

A Hong Kong Entity should register a CbC Reporting Account under the CbC Reporting Portal for accessing the services provided thereunder. The person authorized to register a CbC Reporting Account for the entity has to possess an e-Cert (Organisational) with AEOI Functions for authentication purposes. More information about the application for e-Cert (Organisational) with AEOI Functions can be found in the website of the Hongkong Post Certification Authority.

If a service provider or the person responsible for managing a non-corporate entity (PRM) is authorized to register and/or operate the CbC Reporting Account, the Department should be informed by a Authorization Form for Registration/Operation of CbC Reporting Account (Form IR1465).

A service provider may act for more than one Hong Kong Entity to register / operate CbC Reporting Accounts and submit CbC Returns. Application for Lead Operator Reference Number (Form IR1466) may be made by the service provider for the facility to access, as a lead operator, the CbC Reporting Accounts of relevant Hong Kong Entities through one single log-in.

For details, please visit https://www.ird.gov.hk/eng/tax/dta_cbc.htm or Connect with Us.