🇭🇰 Hong Kong SAR, China
East Asia & Pacific · ISORA participant · ITTI survey participant
Hong Kong SAR, China utilizes artificial intelligence and machine learning for risk scoring in practice and mandates statutory country-by-country reporting. The jurisdiction does not employ automated bulk data matching, controlled foreign company rules, or interest limitation rules. Tax revenue accounted for 14.1% of GDP in 2022.Auto-generated summary of the verified data below; every fact traces to a source on this page.
14.1%
tax-to-GDP, general govt (2022, OECD)
8/11
enforcement powers assessed
Where the tax bite lands (2022)
Tax revenue by category, % of GDP, general government — OECD Revenue Statistics (Global).
Who collects it (2022)
| Level of government | % of GDP |
|---|---|
| Central government | 14.1% |
Tax-to-GDP over time
| 2010 | 2019 | 2022 |
|---|---|---|
| 13.3% | 12.2% | 14.1% |
General government, OECD Revenue Statistics (Global).
Headline statutory rates
As stated in PwC Worldwide Tax Summaries’ territory overview (fetched 2026-08-20) — the wording is PwC’s; source.
| Tax | Headline rate as stated |
|---|---|
| Headline PIT rate | 16 |
| Headline CIT rate | Corporations: 16.5; Unincorporated businesses: 15 |
| Standard VAT rate | NA |
| Headline individual capital gains tax rate | NA |
| Headline corporate capital gains tax rate | NA |
| WHT rates (%) (Dividends/Interest/Royalties) | Resident: 0 / 0 / 0; Non-resident: 0 / 0 / 2.475 to 4.95 |
| Headline net wealth/worth tax rate | NA |
| Headline inheritance tax rate | NA |
| Headline gift tax rate | NA NA stands for Not Applicable (i.e. the territory does not have the indicated tax or requirement) NP stands for Not Provided (i.e. the information is not currently provided in this chart) |
Enforcement powers
AI & machine-learning risk scoring Yes — documented practice
Self-reported in the OECD Inventory of Tax Technology Initiatives (2024 Global Survey on Digitalisation).
“Survey question "Administration uses artificial intelligence" — answer: Yes”
Source: OECD Inventory of Tax Technology InitiativesOECD / IMF survey data · derived from the administration’s own survey answer
Automated bulk data matching No — power absent
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration undertakes fully automated compliance checks based on data matching/analysis" — value: No”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Crypto-asset reporting Partial / committed
Listed by the OECD Global Forum as committed to implement the Crypto-Asset Reporting Framework in time for first exchanges by 2028 (list updated 17 June 2025).
“Costa Rica, Hong Kong (China), Kenya”
Source: OECD Global Forum — Jurisdictions committed to implement the Crypto-Asset Reporting FrameworkOfficial source · quote machine-verified 2026-08-25
Citizenship-based taxation No — power absent
Hong Kong SAR taxes individuals on a territorial basis (local-source income), not by citizenship (PwC Worldwide Tax Summaries).
“Hong Kong SAR adopts a territorial basis of taxation.”
Source: PwC Worldwide Tax Summaries — Hong Kong SARProfessional / legal analysis · quote machine-verified 2026-08-25
Controlled foreign company (CFC) rules No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there a controlled foreign company rule in place? · Not applicable" — No”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Interest limitation rules No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there an interest limitation rule in place? · Not applicable" — No”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Country-by-country reporting Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (0).
“OECD Corporate Tax Statistics: "Is there a country-by-country reporting law in place?" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Public naming of non-compliant taxpayers No — power absent
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure" — value: No”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Anti-avoidance regime detail (OECD Corporate Tax Statistics)
OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation, CbCR and IP-regime rules.
CFC rules — 10 data points
| Is there a controlled foreign company rule in place? · Regime 1 | No |
| Is there a controlled foreign company rule in place? · Not applicable | No |
| Controlled foreign company rule · Regime 1 | Not applicable |
| Controlled foreign company rule · Not applicable | Not applicable |
| Significant controlled foreign company exemption and exclusion requirements · Regime 1 | Not applicable |
| Significant controlled foreign company exemption and exclusion requirements · Not applicable | Not applicable |
| Substantial activity requirements · Regime 1 | Not applicable |
| Substantial activity requirements · Not applicable | Not applicable |
| Year of introduction of the controlled foreign company rule · Regime 1 | Not applicable |
| Year of introduction of the controlled foreign company rule · Not applicable | Not applicable |
Interest limitation — 3 data points
| Is there an interest limitation rule in place? · Rule 1 | No |
| Is there an interest limitation rule in place? · Not applicable | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 1 | Yes |
Country-by-country reporting — 5 data points
| Is there a country-by-country reporting law in place? | Yes |
| Further information | Voluntary parent surrogate filing is or was available for earlier fiscal years. |
| Deadline by which filings must be submitted | 12 months |
| Reports are required for MNEs with annual revenues above | HKD 6.8 billion |
| Headquarter jurisidiction filing required from | 01-Jan-18 |
IP regimes — 6 data points
| Further information · Regime 1 | New regime, designed in compliance with FHTP standards. |
| Regime name · Regime 1 | IP regime |
| Status of the IP regime as determined by the OECD’s Forum on Harmful Tax Practices (FHTP). · Regime 1 | Not harmful |
| Asset types that can qualify for the IP regime · Regime 1 | Patents, Software |
| Tax rate that would otherwise apply · Regime 1 | 16.50% |
| Reduced tax rate that applies under the IP regime · Regime 1 | 5.00% |
Effective corporate tax rates
| Measure | Year | Rate |
|---|---|---|
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 16.5% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 9.1% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 14.3% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 16.5% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 11.8% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 15.3% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 9.7% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 12.3% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 15.0% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 12.8% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 11.6% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 13.1% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 14.3% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 15.8% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 14.4% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 13.9% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | -7.5% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 2.7% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 13.7% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 4.7% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | -0.2% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | -7.7% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 2.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 13.8% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 2.7% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | -0.8% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 5.5% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 6.1% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 6.7% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 6.2% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 5.9% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 2.8% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 3.1% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 3.4% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 3.1% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 3.0% |
OECD Corporate Tax Statistics, baseline scenario.
Administration self-reported metrics (ISORA)
Reported by the administration itself to the IMF/OECD/CIAT/IOTA International Survey on Revenue Administration. 1 = yes, 0 = no for policy questions.
| Indicator | Year | Value |
|---|---|---|
| Percentage of tax returns - Electronic, not prefilled - CIT | 2024 | 0.6812210779347286 |
| Percentage of tax returns - Electronic, not prefilled - PIT | 2024 | 34.60509274503348 |
| Population per FTE | 2024 | 2541.067207024654 |
| Labor force per FTE | 2024 | 1295.416075650118 |
| Corporate taxpayers per FTE in LTO/P | 2024 | 73.44444444444444 |
| Active taxpayers on PIT register as percentage of Population | 2024 | 37.9143419146476 |
| Active taxpayers on PIT register as percentage of Labor Force | 2024 | 74.37215943678996 |
| Closing stock of collectable arrears as percentage of closing stock of arrears | 2024 | 76.70370569484076 |
| CIT arrears as percentage of CIT collected | 2024 | 19.84830954525355 |
| PIT arrears as percentage of PIT collected | 2024 | 10.83984900825802 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - PIT | 2021 | 26.4644989 |
| Additional assessments raised through all audits and verification actions as percentage of tax collections | 2024 | 1.323784752553329 |
| Audit hit rate | 2024 | 34.50954283177985 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, not modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - PIT | 2024 | 0 |
| Availability of specific powers in legislation / regulation to assist in collecting tax arrears | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Common administrative penalty framework for non-disclosure across the major tax types | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Penalties imposed generally take account of taxpayers' culpability (i.e. degree of blame) | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to remit / reduce penalties in appropriate circumstances | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure | 2022 | 0 |
| On-time filing rate % - CIT | 2024 | 65.29814780578077 |
| On-time filing rate % - PIT | 2024 | 80.63215612646628 |
| On-time filing rate % - VAT | 2019 | — |
| On-time filing rate % - PAYE | 2019 | — |
| Administration pre-fills PIT returns or assessments | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Income information: Wages and salaries | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Income information: Pension | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Taxpayer personal information | 2024 | 1 |
| Administration conducts random audits | 2022 | 1 |
| E-filing mandatory - CIT | 2022 | 0 |
| E-filing mandatory - PIT | 2022 | 0 |
| E-payment mandatory - CIT | 2022 | 0 |
| E-payment mandatory - PIT | 2022 | 0 |
| Employers withholding taxes on behalf of salaried employees | 2024 | 0 |
| Percentage of payments received electronically-By number of payments | 2024 | 72.26 |
| Percentage of payments received electronically-By value of payments | 2024 | 30.75 |
| Cooperative compliance approach exists for -Large taxpayers | 2024 | 0 |
| Cooperative compliance approach exists for -HNWI taxpayers | 2024 | 0 |
| Cooperative compliance approach exists for -Other taxpayers | 2024 | 0 |
| Administration receives data from devices that register transactions | 2024 | 0 |
| Administration uses electronic compliance checks as part of returns filing process | 2024 | 1 |
| Administration has specialized audit staff for international tax issues | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Customs data | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from stock exchanges | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from the Social Security Agency | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from online (internet-based) vendors | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from Utilities | 2022 | 0 |
| Administration checks the quality of data reported by third parties on a systematic basis | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data on property ownership and sales | 2022 | 1 |
| Administration undertakes fully automated compliance checks based on data matching/analysis | 2022 | 0 |
| Administration measures the effectiveness of any compliance interventions undertaken | 2022 | 1 |
| Administration has standards for auditor productivity | 2022 | 1 |
Tax technology survey answers (OECD ITTI)
| Question | Answer |
|---|---|
| Personal income tax returns are automatically prefilled with income information | Yes |
| Personal income tax returns are automatically prefilled with expense/allowance information | Yes |
| Administration requires individuals to use an approved digital identity to access secure digital services | Yes |
| Administration requires businesses to use an approved digital identity to access secure digital services | Yes |
| Administration automatically prefills personal income tax returns with data that it has collected | Yes |
| Administration automatically prefills corporate income tax returns with data that it has collected | No |
| For certain personal income taxpayers, the administration prefills tax returns with all necessary data so that they do not need to change the return | No |
| Digital identities provided for individuals are interoperable (if several bodies can provide a digital identity) | No |
| Digital identities for businesses are interoperable (if several bodies can provide a digital identity) | No |
| Estimated percentage of the individual taxpayer population that uses an approved digital identity to access secure digital services offered by the administration | 21-40% |
| Estimated percentage of the business taxpayer population that uses an approved digital identity to access secure digital services offered by the administration | 0-20% |
| Online marketplaces (incl. sharing and gig economy) | No |
| Other online platforms, e.g. stock trading, currencies (incl. crypto). | No |
| Taxpayer accounting systems | Yes |
| E-invoicing systems | No |
| Online cash registers | No |
| Other government entities | Yes |
| Private entities such as banks and insurance companies | No |
| Other jurisdictions (beyond data received under CRS, FATCA and DAC) | No |
| Administration has a comprehensive data management strategy | Yes |
| Administration assesses data quality of reported data | Yes |
| Administration has in place a data ethics framework | Yes |
| Administration controls user data access and security | Yes |
| Administration automatically detects unauthorised access | Yes |
| Administration employs a Data Privacy Officer | Yes |
| Administration has a cyber security unit | Yes |
| Administration hires external parties to test the security of its systems | Yes |
| Administration uses artificial intelligence as part of the data governance process | No |
| Administration has big data capabilities with the necessary people, skills and infrastructure | No |
| Administration uses an enterprise-wide Business Intelligence and Visualisation tool | No |
| Administration uses analytics for real-time tax fraud detection and prevention | No |
| Underlying digital identity solution for individuals is built upon an existing domestic identity system or completely new | Completely new system |
| Underlying digital identity solution for businesses is built upon an existing domestic identity system or completely new | Completely new system |
| Cloud storage | Yes |
| Robotic process automation | Yes |
| Artificial intelligence | No |
| Machine learning | No |
| Network analysis | No |
| DataOps approach | No |
| Automated provision of personalised information to stakeholders | No |
| Virtual assistants | No |
| Risk assessment processes | No |
| Detection of tax evasion and fraud | No |
| Assistance of tax officials in making administrative decisions | No |
| Making recommendations for actions | No |
| Making of final administrative decisions | No |
| Dispute resolution | No |
| To ensure the integrity of tax administration systems / processes | No |
| Other use cases | Yes |
| Administration reviews artificial intelligence source code | No |
| Administration reviews artificial intelligence input information | Yes |
| Administration probes and tests artificial intelligence responses | Yes |
| Administration monitors artificial intelligence outputs | Yes |
| Administration takes other approaches | No |
| Third party reviews artificial intelligence source code | No |
| Third party reviews artificial intelligence input information | No |
| Third party probes and tests artificial intelligence responses | No |
| Third party monitors artificial intelligence outputs | No |
| Third party takes other approaches | No |
| Industry, international or other framework was adopted for the development of the digital identity solution for individuals | Yes, for the whole digital identity solution |
| Industry, international or other framework was adopted for the development of the digital identity solution for businesses | Yes, for the whole digital identity solution |
| Digital identity solution for individuals can connect with foreign identity systems | No |
| Digital identity solution for businesses can connect with foreign identity systems | No |
| Digital identity for individuals created automatically or on request | On request |
| Digital identity for businesses created automatically or on request | On request |
| Meeting needed to finalise the process of receiving a digital identity for individuals | Sometimes |
| Meeting needed to finalise the process of receiving a digital identity for businesses | Sometimes |
| Individuals without ID-documents or birth certificates can receive a digital identity for the use of tax purpose | No |
| Authentication method applied to verify the digital identity when used online | Yes |
| Use of emerging and innovative technologies or solutions with respect to the main digital identity used by taxpayers | No |
| Administration offers online service for registering for tax (CIT) | Yes |
| Administration offers online service for registering for tax (PIT) | Yes |
| Administration offers online service for filing tax returns (CIT) | Yes |
| Administration offers online service for filing tax returns (PIT) | Yes |
| Administration offers online service for making tax payments (CIT) | Yes |
| Administration offers online service for making tax payments (PIT) | Yes |
| Administration offers online service for requesting extensions of deadlines (filing and payment) (CIT) | No |
| Administration offers online service for requesting extensions of deadlines (filing and payment) (PIT) | No |
| Administration offers online service for asking for tax payment arrangements (CIT) | No |
| Administration offers online service for asking for tax payment arrangements (PIT) | No |
| Administration offers online service for asking confidential enquiries in a secure environment (CIT) | No |
| Administration offers online service for asking confidential enquiries in a secure environment (PIT) | Yes |
| Administration offers online service for filing tax related objections (CIT) | No |
| Administration offers online service for filing tax related objections (PIT) | Yes |
| Administration offers online service for dealing with correspondence (CIT) | No |
| Administration offers online service for dealing with correspondence (PIT) | Yes |
| Administration offers online service for uploading data into the tax administration's system (CIT) | Yes |
| Administration offers online service for uploading data into the tax administration's system (PIT) | Yes |
| Administration offers specific approaches to those that do not have online access | Yes |
| Administration offers facility for taxpayers to interact with virtual assistants, such as chatbots | Yes |
| Administration uses artificial intelligence during interactions with taxpayers (other than virtual assistants) | No |
| Administration offers services that follow a set of pre-programmed and automated service responses during interactions with taxpayers (other than virtual assistants) | Yes |
| Administration has an enterprise data management (governance) system that allows taxpayer information be viewed across the administration | No |
| Administration uses big data for analytical purposes | No |
| Administration uses artificial intelligence | Yes |
| Limitations exist on the use of artificial intelligence | Yes |
| Administration has an ethical framework for the application of artifical intelligence | No |
| Administration uses Distributed Ledger Technology, e.g. blockchain, in its taxation processes | No |
| Mobile app | Yes |
| Re-validating the digital identity | Yes |
| Virtual assistant(s) follows a set of pre-programmed rules during interactions with taxpayers | Yes |