Understanding Hong Kong’s Tax Filing Deadlines for 2024/25

Navigating Hong Kong’s tax filing system requires precision and timely compliance. The Inland Revenue Department (IRD) has established clear deadlines for the 2024/25 year of assessment, with distinct timelines for individual taxpayers, corporations, and sole proprietors. Missing these deadlines can result in substantial penalties, surcharges, and even prosecution. This comprehensive guide provides detailed information on all critical deadlines, the automatic eTAX extensions available, and the serious consequences of late filing.

On 2 May 2025, the IRD issued approximately 2.66 million individual tax returns (Form BIR60) for the 2024/25 year of assessment. Meanwhile, profits tax returns for corporations and partnerships were bulk-issued on 1 April 2025. Understanding the various deadlines and extension mechanisms is essential for maintaining compliance and avoiding penalties.

Individual Tax Return Deadlines (Form BIR60)

Standard Filing Deadlines for 2024/25

For the 2024/25 year of assessment, the IRD issued individual tax returns on 2 May 2025. The filing requirements are structured as follows:

Taxpayer Category	Paper Filing Deadline	eTAX Filing Deadline	Extension Period
General Cases (Salaried Employees)	2 June 2025	2 July 2025	Automatic 1 month
Sole Proprietors (Unincorporated Businesses)	2 August 2025	2 September 2025	Automatic 1 month

Automatic eTAX Extension Benefits

The IRD actively promotes electronic filing through its eTAX system by offering an automatic one-month extension. This extension is granted without requiring a separate application, provided the return is filed electronically. For professionally represented taxpayers who apply at least 7 working days before the original due date, a further one-month extension may be granted if the 2024/25 tax returns, including financial statements and tax computations, are filed through the internet.

The benefits of eTAX filing include:

• Automatic Extension: No application required for the initial one-month extension
• Convenience: File returns 24/7 from anywhere with internet access
• Instant Confirmation: Immediate acknowledgment of successful submission
• Faster Processing: Electronic returns are typically processed more quickly
• Environmental Benefits: Reduces paper consumption and administrative burden

Notification of Chargeability Requirements

Even if you do not receive a tax return, you are legally required to notify the IRD of your chargeability to tax if you have taxable income during the year of assessment. This notification must be made within 4 months from the end of the basis period. For example:

• For income earned in the year ending 31 December 2024, notification must be made by 30 April 2025
• For income earned in the year ending 31 March 2025, notification must be made by 31 July 2025

Failure to notify chargeability is a serious offense that can result in penalties under Section 80 of the Inland Revenue Ordinance, even if no tax return was issued to you.

Profits Tax Return Deadlines and Block Extension Scheme

Standard Profits Tax Filing Requirements

The IRD bulk-issued profits tax returns for the 2024/25 year of assessment on 1 April 2025 to all corporations and partnership businesses classified as “active” in the Department’s records. The general rule requires that profits tax returns and any required supplementary forms be filed within 1 month from the date of issue. The specific compliance date is printed on page 1 of the Profits Tax Return.

Understanding Accounting Date Codes

The Block Extension Scheme, available to tax representatives registered with the IRD, provides extended filing deadlines based on the company’s accounting year-end. Companies are assigned one of the following accounting date codes:

Code	Accounting Period End Date	Standard Deadline	Extended Deadline (Block Scheme)
N Code	1 April 2024 to 30 November 2024	1 May 2025	No extension available
D Code	1 December 2024 to 31 December 2024	1 May 2025	15 August 2025
M Code	1 January 2025 to 31 March 2025	1 May 2025	17 November 2025
M Code (Loss Cases)	1 January 2025 to 31 March 2025	1 May 2025	2 February 2026

Special Provisions for M Code Loss Cases

Companies with M code accounting year-ends (31 January, 28/29 February, or 31 March) that incur tax losses in the 2024/25 assessment year may obtain a further extension until 2 February 2026. However, this represents the absolute final deadline, and it will not be extended further even if electronic filing is adopted for such cases.

Tax representatives must submit applications for this special extension on or before 3 November 2025, specifying the IRD file number for each case in a schedule. The IRD Commissioner issued detailed guidance on this scheme in the Circular Letter to Tax Representatives dated 19 March 2025.

Block Extension Scheme Application Process

Tax representatives who wish to utilize the Block Extension Scheme must:

1. Be registered with the IRD as an authorized tax representative
2. Register for Tax Representative Portal Business Accounts if not already done
3. Select “Block Extension Scheme for Lodgement of Tax Returns for the Current Year by Tax Representatives”
4. Lodge applications and notifications electronically through the portal
5. Submit applications before the specified deadlines for each accounting date code

The IRD strongly recommends using the electronic lodgement facility for efficiency and to ensure timely processing of extension applications.

Important Restrictions on Further Extensions

Any request for extension beyond the Block Extension Scheme due dates must be made in writing with a detailed explanation of why lodgement cannot be made in a timely manner, together with supporting evidence. Extensions beyond the Block Extension Scheme dates will only be granted in the most exceptional circumstances, such as:

• Serious illness or hospitalization of key personnel
• Natural disasters affecting business operations
• Unforeseen technical difficulties beyond the taxpayer’s control
• Complex tax issues requiring IRD clarification

New Electronic Filing Requirements for 2024/25

From the 2024/25 year of assessment onwards, all supplementary forms must be filed electronically in XML or iXBRL format, even if the main profits tax return is submitted on paper. This mandatory requirement applies to various supplementary forms including:

• Form S1 (Disposal of Capital Assets)
• Form S2 (Profits or Losses from Businesses Outside Hong Kong)
• Form S8 (Personal Assessment)
• Form S21 (Tax Certainty Enhancement Scheme for Onshore Equity Disposal Gains)

Taxpayers and tax representatives must ensure their systems are capable of generating and submitting these electronic formats to maintain compliance.

Employer’s Return Requirements

Employers have specific obligations under the Inland Revenue Ordinance to file annual returns of remuneration and pensions (Form IR56B, IR56E, IR56F, and IR56G). The deadline for employer’s returns is strictly 1 month from the date of issue, with no automatic extensions available.

Key points for employers:

• No Extensions: Unlike individual and profits tax returns, employer’s returns do not qualify for automatic extensions
• Electronic Filing: Employers are strongly encouraged to use the IR56 e-Filing service
• Strict Penalties: Late filing attracts compound penalties and potential prosecution
• Third-Party Reporting: Failure to file can result in recovery notices being issued to the employer

Late Filing Penalties Under Section 80

Prosecution and Compound Penalties Framework

Section 80 of the Inland Revenue Ordinance provides the IRD with comprehensive powers to penalize taxpayers who fail to file returns on time or fail to notify chargeability. The Department’s policy framework distinguishes between compound penalties and prosecution, depending on the severity and nature of the offense.

Section 80(5) Compound Penalties

For most cases involving late filing of salaries tax or property tax returns, the IRD’s policy is normally to compound such offenses under Section 80(5). The standard compound penalty amounts are:

• First Offense: HK$10,000 fixed penalty for late filing of a valid tax return
• Subsequent Offenses: Higher penalties may apply for repeated violations
• Failure to Notify Chargeability: Similar penalty structure applies even without a return being issued

The compound penalty is designed to encourage compliance without the need for formal prosecution. However, accepting a compound penalty does not exempt the taxpayer from the obligation to file the outstanding return or from paying any surcharges on late tax payments.

Section 80(2) Prosecution

In cases of repeated offenses of the same nature or where the degree of culpability is considered serious, the IRD may institute prosecution actions under Section 80(2). Prosecution may result in:

• Court Fines: Up to HK$50,000 for late filing violations
• Additional Daily Penalties: Up to HK$1,000 per day for continued non-compliance
• Criminal Record: Conviction results in a criminal record
• Imprisonment: In extreme cases, imprisonment for up to 6 months
• Adverse Publicity: The IRD may publicize prosecution cases as a deterrent

The Department considers the following factors when deciding whether to prosecute:

1. History of compliance (prior offenses significantly increase prosecution risk)
2. Degree of cooperation with the IRD during investigations
3. Amount of tax involved
4. Evidence of deliberate avoidance or willful neglect
5. Public interest considerations

Additional Tax Penalties Under Section 82A

Understanding Section 82A Provisions

Section 82A of the Inland Revenue Ordinance empowers the Commissioner of Inland Revenue to assess additional tax on taxpayers who, without reasonable excuse:

• Make an incorrect return by omitting or understating income
• Make an incorrect statement in connection with a claim for deduction or allowance
• Give any incorrect information in relation to any matter or thing affecting their own or another person’s liability to tax
• Fail to submit tax returns on time, resulting in understated tax liability

Significant Scope of Section 82A

Critically, Section 82A makes no distinction between transgression for understatement of income and late filing of returns. This means the exposure to additional tax of up to three times the amount of tax undercharged is applicable to both scenarios. This represents one of the most severe penalty provisions in Hong Kong tax law.

Additional Tax Assessment Process

Before invoking Section 82A, the Commissioner or deputy will follow a structured procedural framework:

1. Written Notice: The IRD issues a written notice indicating the intention to assess additional tax and setting out particulars of the alleged offense
2. Opportunity for Representations: The taxpayer is invited to submit written representations and evidence
3. Minimum 21-Day Period: At least 21 days from the date of service of the notice is given to make representations
4. Assessment Decision: The Commissioner considers all representations before making a final assessment decision
5. Right of Appeal: A person assessed to additional tax has the right to appeal to the Board of Review within one month from the date of issue of the notice of additional tax assessment

Factors Affecting Additional Tax Amount

The IRD uses a framework under Section 82A to determine the quantum of additional tax, considering factors such as:

• Cooperation Level: Degree of assistance provided to the IRD during investigation
• Attitude: Whether the taxpayer shows remorse and takes corrective action
• Disclosure Quality: Completeness and accuracy of voluntary disclosures
• Knowledge and Sophistication: Whether the taxpayer should have known better
• Amount of Tax Involved: Larger understatements typically attract higher penalty percentages
• Deliberate Intent: Evidence of intentional evasion versus negligent error

The additional tax can range from a nominal amount to the maximum of three times the tax undercharged, depending on these factors.

Policy Exceptions for Routine Cases

For salaries tax and property tax cases that do not involve any field audit or investigation, the IRD’s policy is normally to compound offenses under Section 80(5) for failure to submit returns in time. Save in exceptional cases, no penalty action under Section 82A will be taken, having regard to the large number of such cases and the relatively small amount of tax typically involved in each case.

However, this policy does not extend to:

• Profits tax cases involving corporations or businesses
• Cases involving deliberate understatement of income
• Cases subject to field audit or investigation
• Repeat offenders with a history of non-compliance

Surcharges on Late Payment of Tax

Two-Tier Surcharge Structure

Late payment of tax attracts separate surcharges that are distinct from penalties for late filing. The IRD imposes a two-tier surcharge structure designed to encourage prompt payment:

Timing	Surcharge Rate	Applied To
Immediately after due date	5%	Total unpaid tax amount (including second installment if first is unpaid)
6 months after due date	Additional 10%	All unpaid amounts (including the original tax and the 5% surcharge)

Critical Impact of First Installment Default

A particularly severe consequence applies when the first installment of tax is not paid by the due date. In such cases:

• The second installment becomes immediately due and payable
• The 5% surcharge is imposed on the total amount of tax in default, including both installments
• This can significantly increase the immediate financial burden on the taxpayer

For example, if the total tax liability is HK$100,000 payable in two installments of HK$50,000 each, and the first installment is not paid on time:

• Both installments (HK$100,000) become immediately payable
• A 5% surcharge of HK$5,000 is immediately imposed
• If the default continues for 6 months, an additional 10% surcharge of HK$10,500 is imposed on the HK$105,000 outstanding
• Total amount due after 6 months: HK$115,500

Compounding Effect of Surcharges

The second surcharge of 10% is calculated on all unpaid amounts, including the first 5% surcharge. This creates a compounding effect that significantly increases the cost of late payment. After 6 months of default, the effective surcharge rate is 15.5% (5% + 10% of 105% = 15.5% of the original tax amount).

Recovery Actions for Tax in Default

Escalating Recovery Measures

The Commissioner of Inland Revenue has extensive powers under Part XII of the Inland Revenue Ordinance to recover tax in default. Recovery actions escalate progressively:

1. Imposition of Surcharges

As detailed above, 5% and 10% surcharges are automatically imposed on unpaid tax amounts.

2. Recovery Notices to Third Parties

If tax inclusive of any surcharge imposed remains unsettled, the IRD will issue recovery notices to third parties who owe or hold money due to the defaulting taxpayer, including:

• Employers: To deduct outstanding tax from salary payments
• Banks: To freeze and remit funds from the taxpayer’s accounts
• Tenants: To redirect rental payments to the IRD
• Debtors: To pay amounts owed directly to the IRD
• Customers: To redirect business receivables to the IRD

Third parties served with recovery notices are legally obligated to comply and can face penalties for non-compliance.

3. Legal Proceedings

The IRD may initiate legal action to recover outstanding tax, including:

• Civil Proceedings: Filing a civil suit to obtain a judgment
• Writ of Fieri Facias: Issuing a writ to levy execution against movable property
• Charging Order: Applying for a charging order on immovable property (real estate)
• Bankruptcy Proceedings: Pursuing bankruptcy against individual taxpayers
• Liquidation Proceedings: Initiating winding-up proceedings against companies

4. Travel Restrictions

In warranted cases, the IRD may apply to the court for a departure prevention direction to prevent the taxpayer from leaving Hong Kong until the tax debt is settled.

Record Retention Requirements

Seven-Year Statutory Requirement

Section 51C of the Inland Revenue Ordinance requires every person carrying on a trade, profession, or business in Hong Kong to keep sufficient records of income and expenditure to enable assessable profits to be readily ascertained. These records must be retained for at least 7 years after the completion of the transactions to which they relate.

Types of Records to Retain

Businesses and individuals must retain comprehensive documentation including:

• Financial Statements: Audited accounts, balance sheets, profit and loss statements
• Books of Account: General ledgers, cash books, sales and purchase ledgers
• Invoices: Sales invoices, purchase invoices, receipts
• Bank Statements: All business and relevant personal bank records
• Contracts and Agreements: Material contracts affecting business operations
• Payroll Records: Employee compensation records, MPF contributions
• Tax Computations: Detailed calculations supporting tax returns filed
• Correspondence with IRD: All communications, notices, and assessments

Format of Records

Records may be kept in English or Chinese, and may be maintained in electronic format provided they can be readily reproduced in legible hard copy form when required by the IRD. Electronic record-keeping systems must have adequate backup and security measures to prevent loss or unauthorized alteration.

Penalties for Inadequate Record Keeping

Failure to keep or retain proper records can result in:

• Prosecution with fines up to HK$100,000
• Additional tax assessments under Section 82A if the lack of records results in incorrect returns
• Estimated assessments by the IRD based on available information, typically resulting in higher tax liabilities
• Adverse inferences drawn during tax audits or investigations

Best Practices for Compliance

Proactive Compliance Strategies

To avoid penalties and surcharges while maintaining good standing with the IRD, taxpayers should adopt the following best practices:

1. Maintain a Tax Calendar

• Record all relevant deadlines for tax return filing
• Set reminders at least 2 weeks before each deadline
• Account for buffer time to address unexpected issues
• Coordinate with tax representatives well in advance

2. Embrace Electronic Filing

• Register for eTAX services early to take advantage of automatic extensions
• Familiarize yourself with the eTAX portal before filing season
• Maintain secure login credentials and update contact information
• Keep electronic copies of filed returns and acknowledgments

3. Engage Professional Tax Representatives

• For businesses with complex affairs, engage qualified tax professionals
• Ensure tax representatives are registered with the IRD for block extension benefits
• Provide complete and accurate information to representatives promptly
• Maintain regular communication throughout the year, not just at filing time

4. Implement Robust Record-Keeping Systems

• Establish systematic procedures for recording all financial transactions
• Use reliable accounting software with backup capabilities
• Conduct regular internal reviews to ensure record completeness
• Store records securely with protection against loss or damage

5. Plan for Tax Payments

• Set aside funds regularly to meet tax obligations
• Review provisional tax assessments and request adjustment if circumstances change
• Apply for installment arrangements if facing genuine financial hardship
• Never delay payment in hope of avoiding detection

6. Respond Promptly to IRD Communications

• Open and read all IRD correspondence immediately
• Respond to queries and requests for information within specified timeframes
• Seek professional advice if you don’t understand an IRD notice
• Keep copies of all correspondence with the IRD

7. Voluntary Disclosure

• If you discover errors in previously filed returns, make voluntary disclosure promptly
• The IRD typically imposes lower penalties for voluntary disclosure than for errors discovered during audit
• Provide complete and honest information in any disclosure
• Seek professional advice on the disclosure process and potential consequences

Special Considerations for 2024/25

Tax Certainty Enhancement Scheme (TCES)

The 2024/25 year of assessment is the first year in which D code and N code taxpayers can pursue non-taxable claims under the Tax Certainty Enhancement Scheme for onshore equity disposal gains. Starting from 2024/25, taxpayers pursuing such non-taxable claims on their onshore equity disposal gains must complete and file Supplementary Form S21 electronically.

Mandatory Electronic Filing of Supplementary Forms

As noted earlier, from 2024/25 onwards, all supplementary forms must be filed electronically in XML or iXBRL format. This represents a significant change in filing requirements and necessitates system upgrades for many taxpayers and tax representatives. Businesses should:

• Verify their accounting systems can generate the required formats
• Test the electronic submission process before the filing deadline
• Seek IT support or software upgrades if current systems are inadequate
• Consult with tax representatives on technical filing requirements

Global Minimum Tax (BEPS 2.0)

Hong Kong has implemented the Global Minimum Tax regime under the OECD’s BEPS 2.0 framework. Sections 80O, 82, and 82A of the Inland Revenue Ordinance set out penalties for non-compliance with reporting and administrative requirements, including failure to file a top-up tax return or top-up tax notification, and wrongdoings in relation to incorrect returns and notifications. Multinational enterprise groups should be aware of these additional compliance obligations and associated penalty provisions.

What to Do If You Miss a Deadline

Immediate Actions

If you realize you have missed a tax filing deadline, take these immediate steps:

1. File Immediately: Submit the outstanding return as soon as possible, even if late
2. Contact the IRD: Proactively communicate with the IRD explaining the circumstances
3. Provide Explanation: If there are genuine reasons for the delay (illness, technical issues), document and explain them
4. Seek Professional Help: Consult a tax professional for guidance on minimizing penalties
5. Pay Any Tax Due: Even if the return is late, pay the tax to avoid surcharges

Responding to IRD Notices

If you receive a penalty notice or Section 82A notice from the IRD:

• Read it carefully and note all deadlines for response
• Prepare detailed written representations within the specified timeframe
• Provide supporting evidence for any mitigating circumstances
• Consider engaging a tax professional to assist with representations
• Be honest and cooperative in all dealings with the IRD
• If you disagree with a penalty assessment, exercise your right to appeal to the Board of Review

Applying for Holdover of Provisional Tax

If you face difficulty paying provisional tax because your income has decreased, you can apply for holdover using Form IR1121. This allows you to reduce provisional tax payments to a level commensurate with your current year’s expected income, helping you avoid overpayment and cash flow difficulties.

Conclusion

Compliance with Hong Kong’s tax filing deadlines is not optional—it is a legal obligation with serious consequences for non-compliance. The 2024/25 year of assessment brings clear deadlines, with individual tax returns due by 2 June 2025 (or 2 July 2025 via eTAX) and profits tax returns due one month from issue date, with possible extensions under the Block Extension Scheme for represented taxpayers.

The penalty framework is comprehensive and severe. Late filing can result in compound penalties of HK$10,000 or prosecution with fines up to HK$50,000 plus daily penalties. Additional tax under Section 82A can reach up to three times the tax undercharged. Late payment surcharges of 5% immediately and an additional 10% after six months compound quickly, significantly increasing the total amount owed.

The most effective strategy is proactive compliance: file on time, pay on time, keep proper records for seven years, and maintain open communication with the IRD. Electronic filing through eTAX offers automatic extensions and greater convenience. For businesses with complex affairs, engaging qualified tax representatives registered for the Block Extension Scheme can provide valuable additional time for preparation and filing.

If you do miss a deadline, act immediately to file the outstanding return, communicate with the IRD, and seek professional advice. The consequences of continued non-compliance are far more severe than those of late but proactive correction.

Sources and References

This article is based on official guidance from the Hong Kong Inland Revenue Department and current tax legislation. Key sources include:

• IRD: Filing of tax return on time
• IRD: Penalty Policy
• Circular Letter to Tax Representatives (2024/25)
• IRD: Tax Representatives’ Corner
• IRD: Block Extension Scheme for Tax Representatives
• GovHK: Consequences of Not Paying Tax On Time
• GovHK: Profits Tax Return and Supplementary Form
• IRD issues tax returns for individuals (2024/25)
• Hong Kong Tax Deadlines 2024/25: The Complete Guide
• KPMG: A quick guide to the 2024/25 Hong Kong Profits Tax filing

Disclaimer: This article is for informational purposes only and does not constitute professional tax advice. Tax laws and IRD policies are subject to change. Readers should consult qualified tax professionals for advice specific to their circumstances.