1. For more details, please refer to our Hong Kong SAR Tax Alert, Issue 3, February 2026 via this link: The government’s proposals on enhancing intellectual property tax deduction in Hong Kong.
2. The Legislative Council brief paper can be accessed via this link: Panel on Commerce, Industry, Innovation and Technology
3. The six types of specified IP rights are (i) copyrights, (ii) performer’s economic rights, (iii) protected layout-design (topography) rights, (iv) protected plant variety rights, (v) registered designs and (vi) registered trade marks.
4. This refers to the notional deduction amount allowable to the seller. It has yet to be seen whether this is intended to cater for the situation where the seller was not able to claim a tax deduction for the purchase cost in a previous year (i.e. under the existing IP tax deduction regime) when it purchased the IP concerned.
5. Qualified R&D expenditure means any expenditure incurred in relation to the R&D activities for which deduction is allowable under section 16B of the Inland Revenue Ordinance.
6. The IRD indicated in the Legislative Council meeting that it will issue further guidance to illustrate the computation of the tax deduction amount.
7. Currently, Singapore requires a third‑party independent valuation report for IP transfers between related parties only where the IP acquisition cost is not less than S$10 million.
8. For more details about the SBTI safe harbour, please refer to our Hong Kong BEPS publication via this link. Please also refer to the FAQs on Global Minimum Tax recently updated by the OECD for discussion on the SBTI safe harbour and treatment of IP tax regimes adopting the OECD’s nexus approach via this link: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/global-minimum-tax/faqs-on-model-globe-rules.pdf
9. For more details, please refer to our webpage on the 2026/27 Hong Kong Budget via this link.