Applying for a multinational enterprise group code with Form IR1485

Purpose of the Group Code Under CbC Reporting

The Inland Revenue Department (IRD) assigns a multinational enterprise group code to identify each multinational enterprise (MNE) group for Country-by-Country Reporting (CbC Reporting) purposes. This group code is a unique identifier used throughout the group’s interactions with the IRD, including the filing of CbC reports and related notifications. The group code is distinct from the Business Registration Number or the Companies Registry number: it specifically links all constituent entities of a single MNE group that has a reporting obligation in Hong Kong.

To obtain this identifier, the ultimate parent entity or the surrogate parent entity of a Hong Kong-headquartered MNE group must submit Form IR1485 multinational enterprise group code. The form is filed with the IRD before any CbC report or notification is due. Without a valid group code, the IRD cannot process the group’s CbC filings, which would place the group in default of its reporting obligations.

The IRD requires every in-scope MNE group that meets the consolidated group revenue threshold to obtain a group code. This code is used on all subsequent CbC-related filings, including the CbC report itself and any notifications required under the Inland Revenue Ordinance (Cap. 112). The group code allows the IRD to track the group’s compliance across multiple years and entities.

Who Must Apply for a Multinational Enterprise Group Code

Any MNE group that is required to file a CbC report in Hong Kong must first obtain a group code using Form IR1485. This includes:

• Ultimate parent entities that are tax resident in Hong Kong and have consolidated group revenue of at least HK$7.5 billion (or the equivalent in another currency) in the preceding fiscal year.
• Surrogate parent entities that have been appointed to file the CbC report on behalf of the MNE group, where the ultimate parent entity is not required to file in its own jurisdiction.
• Constituent entities that are resident in Hong Kong and are required to file a CbC report because the ultimate parent entity has not filed one in its jurisdiction of residence.

The group code is applied for per MNE group, not per entity. A single application covers all Hong Kong constituent entities that belong to that group. If a group has multiple constituent entities in Hong Kong, the entity submitting the application (usually the ultimate parent or a designated entity) must provide details on all of them.

Applying for a Form IR1485 Multinational Enterprise Group Code

The group code is required for any MNE group that has a Hong Kong reporting obligation under the CbC Reporting framework. This includes groups where:

• The ultimate parent entity is tax resident in Hong Kong.
• A constituent entity of the group is tax resident in Hong Kong and the ultimate parent entity is resident in a jurisdiction that does not have a CbC exchange agreement with Hong Kong.
• A surrogate parent entity has been appointed and is resident in Hong Kong.

Even if the MNE group does not have a current reporting obligation, the IRD may require a group code if a notification or other filing is triggered. The group code is a one-time application: once assigned, it remains with the MNE group for all future reporting years unless the group’s structure changes materially (for example, a merger or acquisition that changes the ultimate parent entity).

Information Required in Form IR1485

Form IR1485 requires the applicant to provide the following information:

• MNE group details:
• Legal name of the MNE group (as registered in its home jurisdiction).
• Jurisdiction of tax residence of the ultimate parent entity.
• Jurisdiction of incorporation or organisation of the ultimate parent entity.
• Applicant entity details:
• Name of the entity submitting the application (the ultimate parent entity, surrogate parent entity, or designated constituent entity).
• Hong Kong Business Registration Number (BRN) of the applicant entity.
• Contact person name, telephone number, and email address.
• Constituent entity list:
• A complete list of all constituent entities of the MNE group that are resident in Hong Kong, including their names, BRNs, and jurisdiction of incorporation.
• For each constituent entity, the role within the group (e.g., holding company, operating company, finance company).
• Reporting history:
• Whether the MNE group has previously been assigned a group code by the IRD.
• If yes, the existing group code.
• Declaration:
• A signed declaration by an authorised person (e.g., director, company secretary, or tax representative) confirming that the information is true and correct.

The form must be completed in English or Chinese. Supporting documents may be required, such as organisational charts or lists of constituent entities.

How the Group Code Is Used for Subsequent Filings

Once the IRD assigns a group code to the MNE group, that code is used for all CbC-related correspondence and filings. Specifically, the group code is required for:

• CbC report filing: The ultimate parent entity or surrogate parent entity must use the group code when filing the CbC report (Form IR1486) through the Business Tax Portal or via paper.
• Notification of CbC filing: Every constituent entity resident in Hong Kong that is part of the MNE group must notify the IRD of its identity and the group code, typically using Form IR1487.
• Amendments or corrections: If the MNE group needs to amend a previously filed CbC report, the group code is referenced in the amended filing.
• Correspondence: All correspondence with the IRD regarding CbC matters, including requests for information or changes of contact details, should reference the group code.

The group code remains valid indefinitely, subject to the group’s continued existence. If the MNE group undergoes a significant restructuring (e.g., a merger that changes the ultimate parent entity), the group may need to submit a new Form IR1485 to update its details. The IRD may also assign a new group code if the original group code is no longer appropriate.

IR1485 Application Requirements

To successfully apply for a group code using Form IR1485, the applicant must ensure the following requirements are met:

• The form is completed accurately, with no missing fields.
• The list of constituent entities is exhaustive and matches the group’s structure as of the filing date.
• The applicant entity has a valid Business Registration Number in Hong Kong.
• The declaration is signed by an authorised person who has legal authority to bind the applicant entity.
• The form is submitted to the IRD at the correct address or through the Business Tax Portal if electronic filing is supported.

The IRD does not currently charge a fee for the application, but this may be subject to change. The processing time is typically within 10 working days, though the IRD may request additional information if the form is incomplete.

The application must be submitted before the deadline for filing the CbC report for the relevant fiscal year. If the group has a retrospective obligation, the IRD may accept a late application, but penalties may apply for late filing of the underlying CbC report.

MNE Group Code IRD Hong Kong: Where to Submit

Form IR1485 should be submitted to:

Inland Revenue Department Inland Revenue Centre, 5 Concorde Road, Kai Tak, Kowloon, Hong Kong

Alternatively, the IRD accepts electronic submissions through the Business Tax Portal. The portal requires the applicant to have a valid eTAX account and digital certificate. The IRD’s website provides detailed instructions on how to access the portal and upload the form.

Applicants should retain a copy of the submitted form and the acknowledgment letter from the IRD confirming the assigned group code. This acknowledgment serves as proof of registration for future filings.

Key Points for Business Owners

• Single group code per MNE group: Only one group code is assigned, even if the group has dozens of constituent entities in Hong Kong. The group code is used for all CbC filings and notifications.
• No fee for initial application: The IRD does not charge a fee for applying, but penalties may apply for late filing of CbC reports.
• Ongoing compliance: Once assigned, the group code must be included in all CbC-related filings and correspondence.
• Changes require update: Any change in the MNE group’s structure or contact details should be notified to the IRD as soon as possible, using a supplementary form or correspondence referencing the group code.

Business owners should discuss the application process with their tax advisor or the group’s tax compliance team to ensure all constituent entities are correctly listed and the application is submitted in time. The IRD’s CbC Reporting guidance notes, available on its website, provide further detail on the requirements for Form IR1485 and the group code system.