Inland Revenue vs Companies Registry Forms: Key Differences for Hong Kong Companies

Inland Revenue vs Companies Registry Forms Hong Kong: Key Differences

Every Hong Kong company answers to two masters. The Companies Registry (CR) and the Inland Revenue Department (IRD) each demand forms, each set their own deadlines, and neither cares whether you filed with the other. The inland revenue vs companies registry forms hong kong distinction is not administrative nuance. It is the difference between staying on the register and staying out of court.

The Companies Registry administers the Companies Ordinance (Cap. 622). Its specified forms govern corporate structure, directors, shareholders and the registered office. The Inland Revenue Department administers the Inland Revenue Ordinance (Cap. 112). Its forms govern profits tax, salaries tax, property tax and employer obligations. A company must file with both registries. The deadlines rarely align.

Difference Between IRD and CR Forms Hong Kong

Companies Registry forms record the legal identity and structure of a company. File Form NAR1 (annual return) and you tell the Registrar who the directors and shareholders are, where the registered office sits, and what the share capital is. File Form ND2A and you record a change of director or company secretary. These filings maintain the public register under Cap. 622.

Inland Revenue forms report financial information for tax assessment. Form BIR51 (profits tax return) tells the IRD how much profit the company made and how much tax it owes. Form BIR56A and IR56B report employee remuneration for salaries tax. The IRD uses these forms to assess tax liabilities under Cap. 112 and the Business Registration Ordinance (Cap. 310).

A company that files its annual return on time but misses its profits tax return is still non-compliant. The two obligations are independent.

Hong Kong Profits Tax Return vs Annual Return

The profits tax return (Form BIR51) and the annual return (Form NAR1) are the two most common recurring filings. They are frequently confused.

Form NAR1 (annual return) is filed with the Companies Registry. It is due within 42 days after the anniversary of the company's incorporation or re-domiciliation. The on-time registration fee for a private company is HK$105. Late delivery attracts a higher registration fee: HK$870 if more than 42 days but within 3 months, HK$1,740 for 3 to 6 months, HK$2,610 for 6 to 9 months, and HK$3,480 for more than 9 months. A private company that has declared itself dormant is exempt from filing NAR1.

Form BIR51 (profits tax return) is filed with the Inland Revenue Department. The IRD issues the return on a basis period that it determines, corresponding to the company's accounting reference date. The deadline is one month from the date of issue. The IRD may grant extensions for companies with accounting periods ending on certain dates. There is no registration fee for filing BIR51. Late filing can result in penalties, estimated assessments, and prosecution.

The annual return reports who the company is. The profits tax return reports what the company earned.

Companies Registry Forms vs Inland Revenue Forms

Hong Kong BIR51 vs NAR1

Form BIR51 and Form NAR1 are the two forms every active Hong Kong company must file annually. They answer different questions.

BIR51 asks how much profit the company made in the basis period, what the assessable profits figure is, and which tax computations and financial statements support that figure. The return must be accompanied by audited financial statements (unless the company qualifies for exemption from audit), a tax computation, and any relevant supplementary forms (S1 to S18) depending on the company's activities.

NAR1 asks who the current directors and company secretary are, what the registered office address is, what the issued share capital and number of shareholders are, and whether the company has changed its accounting reference date. The return does not ask for financial figures.

A company that files NAR1 but not BIR51 will remain on the register. It may also face IRD enforcement action, including estimated assessments and prosecution. A company that files BIR51 but not NAR1 will eventually be struck off the register for non-compliance with Cap. 622.

Filing Channels: e-Services Portal vs Business Tax Portal

The Companies Registry operates the e-Services portal at https://www.eregistry.gov.hk/. Through this portal, users can file specified forms electronically, including NAR1, ND2A, NR1, and NSC1. The portal also allows users to search the public register and order certified true copies of documents.

The Inland Revenue Department operates the Business Tax Portal at https://www.ird.gov.hk/eng/tax/bus_epf.htm. Companies and their tax representatives can file profits tax returns, employer returns, and other IRD forms electronically through this portal. From the year of assessment 2025-26, mandatory electronic filing of profits tax returns began for relevant entities of in-scope multinational enterprise groups. Electronic filers must tag financial statements and tax computations in iXBRL format. The IRD has stated an intention to reach full electronic filing by 2030.

A company that files with both registries must maintain access to both portals. The e-Services portal and the Business Tax Portal are separate systems with separate login credentials.

Business Registration and the Overlap

One form sits at the intersection of the two registries: Form IRBR1. This form is a notice to the of the Inland Revenue Department, but it is filed together with the incorporation forms NNC1 or NNC1G at the Companies Registry. When you incorporate a company, the Companies Registry forwards the business registration information to the IRD. The IRD then issues a Business Registration Certificate under Cap. 310.

After incorporation, business registration renewal is handled separately by the IRD. The Companies Registry has no role in it. A company must renew its Business Registration Certificate annually or every three years, regardless of its annual return filing.

Practical Summary for Business Owners

• File Form NAR1 with the Companies Registry within 42 days of the return date. Pay the registration fee on time to avoid the higher registration fee.
• File Form BIR51 with the IRD by the deadline stated on the return. Attach audited financial statements and a tax computation.
• File employer returns (BIR56A and IR56B) with the IRD by the annual deadline of 1 April for the preceding year.
• Notify the Companies Registry of any change of director, company secretary, registered office, or share capital using the appropriate specified form (ND2A, ND2B, NR1, NSC1, etc.).
• Notify the IRD of a new employee using Form IR56E, and of a departing employee using Form IR56F or IR56G.
• Maintain access to both the e-Services portal and the Business Tax Portal.
• Check the Companies Registry specified forms index at https://www.cr.gov.hk/en/forms/specified.htm and the IRD forms index at https://www.ird.gov.hk/eng/paf/bus.htm for the latest versions of each form. The registries revise forms periodically. A stale copy is worse than none.