Decoding Hong Kong’s eTAX Notifications: How to Respond to IRD Communications
Key Facts: Hong Kong IRD Communications
- Standard Response Deadline: 1 month from the date of issue for tax returns and objections
- Electronic Filing Extension: Automatic 1-month extension when filing via eTAX
- Record Retention: Minimum 7 years from transaction date (Section 51C IRO)
- Objection Process: Governed by Section 64 of the Inland Revenue Ordinance
- Appeal Timeframe: 1 month from Commissioner’s determination to appeal to Board of Review
- Message Retention: Electronic notices kept in eTAX for 6 years from issue date
- Late Filing Penalty: Up to HKD 10,000, plus additional tax of up to 3x unpaid amount
- Record-Keeping Penalty: Up to HKD 100,000 for non-compliance
In Hong Kong’s increasingly digitalized tax environment, understanding how to properly receive, interpret, and respond to Inland Revenue Department (IRD) communications through the eTAX platform has become essential for taxpayers. Whether you’re receiving your first tax return or dealing with a complex assessment query, knowing the proper procedures and deadlines can save you from penalties, additional charges, and unnecessary stress.
This comprehensive guide explains the types of IRD notifications you’ll encounter, the response requirements for each, and the critical procedures you need to follow to maintain compliance with Hong Kong’s tax laws.
Understanding the eTAX Notification System
What is eTAX?
The eTAX platform is Hong Kong’s comprehensive digital tax portal, launched by the Inland Revenue Department to streamline tax administration and communication. As of August 14, 2024, the IRD deployed an enhanced version of the eTAX portal featuring an intuitive, mobile-responsive design that allows taxpayers to manage their obligations from any device, whether desktop, tablet, or smartphone.
The platform provides real-time reminders, e-notices, and e-alerts directly in your account, helping you stay on top of important dates for tax return submission and payments. This paperless approach means everything from tax returns to official notices is delivered in electronic format, creating a centralized hub for all your tax communications.
eTAX Message Box Structure
The eTAX notification center is organized into two primary sections:
| Message Section | Purpose | Content |
|---|---|---|
| Inbox | Receive communications | Messages from IRD and messages sent by authorized representatives via Tax Representative Portal (TRP) |
| Outbox | Track sent communications | Messages sent by you to IRD via the Individual Tax Portal (ITP) |
All electronic notices and documents are retained in the Message Box for 6 years from the date of issue, providing you with a comprehensive archive of your tax communications. Additionally, upon your selection, email notifications can be sent to your registered email address to alert you when new messages arrive in your inbox.
Types of Alert Messages
The eTAX system sends various types of alert messages to keep you informed:
- Return Filing Reminders: Approximately one week before the return filing due date, you’ll receive an alert message with links to view the electronic notice, check Internet filing criteria, and file your return online
- Payment Due Alerts: About one week before the tax payment due date, an e-alert reminds you of your tax liability for Salaries Tax, Property Tax, Profits Tax, or Personal Assessment
- Payment Receipts: Electronic receipts are sent to your inbox (regardless of your preference for electronic notices) within approximately 2 working days after the IRD receives your payment
- Assessment Notices: Official notifications of tax assessments and determinations
Types of IRD Communications and How to Respond
1. Tax Returns (Form BIR60 for Individuals)
Tax returns are issued annually to taxpayers, requiring them to declare their income and claim relevant deductions. For the 2024/25 tax year, individual tax returns were issued on May 2, 2025.
Response Requirements:
- Standard Deadline: 1 month from the date of issue (e.g., June 2, 2025 for returns issued May 2, 2025)
- Electronic Filing Extension: Automatic 1-month extension if filing electronically via eTAX
- Sole Proprietors: Extended deadline (e.g., August 2, 2025 for 2024/25 returns)
- Block Extension Scheme: Further extensions available for professionally represented taxpayers through tax representatives
Action Steps:
- Log in to your eTAX Individual Tax Portal (ITP) account
- Review the tax return notice in your Message Box inbox
- Gather all relevant income documentation, receipts for deductions, and supporting records
- Complete the return electronically through the eTAX platform to benefit from the automatic extension
- Review all entries carefully before submission
- Submit before the deadline and retain the acknowledgment receipt
2. Demand Notes (Tax Bills)
A tax demand note is an official document issued by the IRD notifying taxpayers of their tax obligations and payment requirements. This document demands immediate attention, as non-compliance can result in penalties, surcharges, and legal consequences.
Demand notes typically include:
- The assessed tax amount due
- Payment deadline (usually within 1 month)
- Shroff account number for payment (prefix 1, 2, 3 for Profits Tax; 5 or 7 for Property Tax; 6 for Personal Assessment; 9 for Salaries Tax)
- Payment methods and instructions
- Provisional tax for the following year (if applicable)
Response Requirements:
- Payment Deadline: As specified on the demand note (typically 1 month from issue date)
- Installment Options: May be available for provisional tax payments
- Objection Period: 1 month from the date of assessment if you disagree with the assessment
Action Steps:
- Review the demand note carefully to verify the assessed amount
- If you agree with the assessment, arrange payment before the due date using eTAX payment services, PPS, internet banking, or other approved methods
- If you disagree with the assessment, prepare and submit a written objection within 1 month (see Objection Process below)
- Keep records of all payment receipts or objection submissions
3. Enquiry Letters and Information Requests
The IRD may issue enquiry letters requesting additional information, clarification, or supporting documentation regarding your tax affairs. These may relate to specific deductions claimed, sources of income, or general compliance reviews.
Response Requirements:
- Standard Deadline: Typically 1 month from the date of the enquiry letter
- Extension Requests: Submit as soon as possible with reasonable explanation if more time is needed
- Complete Response: Provide all requested information and supporting documents
Action Steps:
- Read the enquiry letter thoroughly to understand exactly what information is being requested
- Gather all relevant documents, records, and evidence (remember: you must retain records for at least 7 years)
- Prepare a clear, organized written response addressing each point raised
- If needed, consult with a tax professional to ensure your response is comprehensive and appropriate
- Submit your response via eTAX (you can upload up to 5 supporting documents with a total file size up to 200MB)
- If you cannot meet the deadline, immediately apply for an extension with a reasonable explanation
- Keep copies of all correspondence and submitted documents
Important Warning: Failure to meet the IRD’s deadlines or provide complete information may lead to additional tax assessments, penalties of up to HKD 10,000, or further scrutiny through formal audits and investigations.
4. Assessment Notices
An assessment notice is the IRD’s formal determination of your tax liability for a particular year of assessment. It may be based on your submitted tax return, estimated by the IRD if you failed to file, or adjusted following a review or audit.
Response Requirements:
- Objection Deadline: 1 month from the date of the notice of assessment (Section 64 IRO)
- Payment Obligation: Tax must be paid notwithstanding any objection, unless a holdover is granted
- Written Format: Objections must be in writing with detailed grounds
The Objection and Appeal Process
Hong Kong’s tax objection and appeal system is governed by Sections 64-66 of the Inland Revenue Ordinance and provides a structured pathway for taxpayers who disagree with IRD assessments or determinations.
Stage 1: Objection to the Commissioner (Section 64)
When an assessment is issued, you have the right to object within one month of the date of the notice of assessment. This is the mandatory first step in challenging any assessment.
Objection Requirements:
- Timing: Submit within 1 month of the assessment notice date
- Format: Written notice (no prescribed form, but must be in writing)
- Content: Detailed grounds explaining precisely why you object to the assessment
- Supporting Evidence: Include relevant documentation and facts supporting your position
The Objection Review Process:
- Initial Review: The original assessor reviews your objection first
- Appeal Section Review: If the assessor believes no changes are warranted, the file is transferred to the IRD’s Appeal Section (a separate unit) for de novo review
- Commissioner’s Determination: The Commissioner reviews the Appeal Section’s recommendations and issues a determination with a statement of facts and reasons
- Possible Outcomes: The determination may confirm, reduce, increase, or annul the original assessment
Critical Requirement – “Pay First, Argue Later”: Under Hong Kong’s tax system, you must pay the assessed tax even if you file an objection, unless the Commissioner grants a holdover of payment. You can apply for a holdover, and the Commissioner has discretion to grant it (potentially requiring security such as a tax reserve certificate or banker’s undertaking).
Applying for Holdover of Tax
To avoid undue financial hardship while your objection is being considered, you can apply to the Commissioner for a holdover of the disputed tax amount.
| Aspect | Details |
|---|---|
| Authority | Commissioner has wide discretion to grant or refuse holdover |
| Security Requirements | May require purchase of tax reserve certificate or banker’s undertaking |
| Interest Rate | 8.875% per annum on held-over tax (effective from January 1, 2024) |
| Application Timing | Should be submitted together with or shortly after the objection |
Stage 2: Appeal to the Board of Review (Sections 65-66)
If you disagree with the Commissioner’s determination of your objection, you can appeal to the Board of Review, an independent statutory tribunal constituted under Section 65 of the IRO.
Appeal Requirements:
- Timing: Within 1 month after receiving the Commissioner’s written determination, reasons, and statement of facts
- Format: Written notice of appeal to the Board of Review with copy to the Commissioner
- Required Documents: Statement of grounds of appeal and copies of the Commissioner’s determination, reasons, and statement of facts
- Nature: The Board acts as an independent trial court conducting de novo hearings
Board of Review Procedures:
- Independent hearing of evidence and arguments
- Both taxpayer and IRD present their cases
- Board issues written determination with findings of fact and reasons
- If the Board does not reduce or annul the assessment, the appellant may be ordered to pay costs up to HKD 25,000
Stage 3: Further Appeals to the Courts
Hong Kong’s tax appeal system includes a unique feature: either the taxpayer or the Commissioner can transfer a case directly from the Board of Review to the Court of First Instance, or appeal the Board’s decision on questions of law.
| Court Level | Jurisdiction | Timeframe |
|---|---|---|
| Court of First Instance (CFI) | Appeals on questions of law from Board decisions; transfer option before Board hearing | Within 1 month of Board decision or notification |
| Court of Appeal (CA) | Appeals from CFI decisions on questions of law | According to court procedural rules |
| Court of Final Appeal | Final appeals on questions of law of great general or public importance | By leave only |
Recent Notable Court Cases (2024):
- Touax Container Investment Limited v CIR (CFI, August 30, 2024): The CFI ruled that the Board of Review erred in its approach to determining the source of profits from container trading and leasing businesses, remitting the case for rehearing on insufficient findings of fact
- Patrick Cox Asia Limited v CIR (CA, October 17, 2024): The Court of Appeal upheld the Board’s decision that upfront payments under a trademark sub-licensing arrangement were revenue in nature and Hong Kong sourced, but found errors in determining that royalty income was sourced in Hong Kong, remitting for rehearing
Record Retention Requirements
Maintaining proper records is not just good business practice—it’s a legal requirement in Hong Kong that directly affects your ability to respond to IRD communications and substantiate your tax positions.
The 7-Year Rule
Under Section 51C of the Inland Revenue Ordinance, all taxpayers must retain business and tax records for a minimum of 7 years from the date of the transaction. This requirement applies to both businesses and individuals with rental or business income.
Practical Examples:
- A company making purchases in 2024 must retain related invoices and receipts until 2031
- Tax filings for 2024/25 must be supported by documents dating back to 2017/18
- Employment records and payroll documentation must be kept for 7 years from the date of each payment
Required Records
The IRD requires the following types of records to be maintained:
| Record Category | Examples |
|---|---|
| Financial Statements | Income statements, balance sheets, cash flow statements |
| Transaction Records | Sales invoices, purchase receipts, bank statements, daily transaction logs |
| Asset and Liability Records | Property purchase documents, loan agreements, depreciation schedules |
| Employment Records | Payroll records, IR56 forms, employment contracts, MPF records |
| Supporting Documentation | Expense vouchers, receipts, contracts, correspondence |
Electronic Record Storage
The IRD permits electronic storage of records, provided they meet specific requirements:
- Readable and Retrievable: Records must remain accessible and readable throughout the retention period
- Stable Formats: Use formats like PDF or XML that won’t become obsolete
- Complete Copies: Ensure you can retrieve full copies during audits or inspections
- Scanning Options: For high-volume documents, scanning and storage on CD-ROMs or secure cloud platforms is acceptable
Penalties for Non-Compliance
Failure to maintain proper records carries serious consequences:
| Violation | Penalty |
|---|---|
| Failing to maintain records for 7 years | Maximum fine of HKD 100,000 |
| Unable to produce records during audit | Disallowance of deductions, reassessment of tax liabilities, additional tax charges |
| Late filing of tax return | Up to HKD 10,000 plus additional tax up to 3x unpaid amount (Section 51 IRO) |
Best Practices for Managing IRD Communications
1. Proactive Monitoring
- Log in to your eTAX account regularly, at least weekly during tax season
- Enable email notifications for all new messages in your eTAX inbox
- Download the eTAX mobile app for real-time access from your smartphone or tablet
- Set calendar reminders for key tax deadlines
2. Organized Record-Keeping
- Implement a systematic filing system (digital or physical) for all tax-related documents
- Create separate folders for each tax year
- Maintain backup copies of all electronic records in multiple locations
- Archive correspondence with the IRD chronologically
- Mark important deadlines clearly on all documents
3. Timely Response Protocol
- Read all IRD communications immediately upon receipt
- Note all deadlines and work backwards to create action timelines
- If you need clarification, contact the IRD promptly rather than waiting until the deadline approaches
- If you cannot meet a deadline, apply for an extension as soon as you realize the issue
- Never ignore IRD communications—penalties escalate with time
4. Professional Assistance
Consider engaging professional help when:
- You receive an enquiry letter about complex tax matters
- You need to file an objection to an assessment
- You’re facing a tax audit or investigation
- You have multiple sources of income or complex tax affairs
- You’re considering an appeal to the Board of Review or courts
- Your business has grown and requires specialized tax planning
Tax representatives can lodge block extension applications electronically and communicate with the IRD through the Tax Representative Portal (TRP), which was enhanced in 2025 to improve efficiency and accuracy.
5. Leverage eTAX Features
The enhanced 2024/25 eTAX platform offers numerous features to simplify tax compliance:
- Document Upload: Upload up to 5 supporting documents (total file size up to 200MB) when requesting amendments or responding to enquiries
- Mobile Responsiveness: Access all functions from smartphones and tablets
- Automatic Extensions: Electronic filing grants automatic 1-month extension for individual returns
- Payment Integration: Make payments directly through the platform
- 6-Year Archive: Access all historical notices and messages from the past 6 years
Understanding Your Taxpayer Rights
As a Hong Kong taxpayer, you have specific rights when dealing with the IRD:
| Right | What It Means |
|---|---|
| Right to Object | You can challenge any assessment you believe is incorrect within 1 month |
| Right to Appeal | If unsatisfied with the Commissioner’s determination, you can appeal to the independent Board of Review |
| Right to Representation | You can engage tax professionals to represent you in dealings with the IRD |
| Right to Request Holdover | You can apply for holdover of tax payment pending objection or appeal (subject to Commissioner’s discretion) |
| Right to Fair Hearing | The Board of Review provides an independent, impartial hearing of tax disputes |
| Right to Judicial Review | You can appeal Board decisions on questions of law to the Court of First Instance and higher courts |
Common Mistakes to Avoid
Critical Errors That Can Cost You:
- Ignoring Communications: Every IRD notice requires attention. Ignoring them leads to escalating penalties and potential legal action
- Missing Deadlines: Even by one day can result in substantial penalties. The 1-month deadline is strictly enforced
- Incomplete Objections: Vague objections without detailed grounds and supporting evidence are likely to be rejected
- Not Applying for Holdover: Assuming you don’t have to pay while objecting is wrong—you must apply for and receive approval for a holdover
- Poor Record-Keeping: Failing to maintain 7-year records makes it impossible to substantiate your position during disputes
- Not Reading Carefully: Misunderstanding what information is being requested leads to incomplete responses and follow-up enquiries
- Going It Alone on Complex Matters: Attempting to handle complex objections or appeals without professional assistance can result in unfavorable outcomes
- Not Using eTAX Features: Filing on paper when electronic filing grants an automatic extension is a missed opportunity
Conclusion
Successfully navigating Hong Kong’s eTAX notification system and IRD communications requires vigilance, organization, and a clear understanding of your obligations and rights. The digitalization of tax administration through the enhanced eTAX platform has made communication more efficient, but it has also placed greater responsibility on taxpayers to monitor their accounts regularly and respond promptly to all notifications.
By understanding the different types of IRD communications, adhering to response deadlines, maintaining proper records for at least 7 years, and knowing the objection and appeal procedures, you can ensure compliance while protecting your interests. Remember that the 1-month deadline applies to most responses, and the “pay first, argue later” principle means you’ll generally need to pay assessed tax while pursuing objections unless you secure a holdover.
The structured appeal process—from initial objection under Section 64, through the Board of Review under Sections 65-66, to the courts—provides robust mechanisms for challenging assessments you believe are incorrect. However, each stage has strict timeframes and procedural requirements that must be followed precisely.
Whether you’re handling routine tax returns or complex disputes, leveraging the features of the eTAX platform, maintaining meticulous records, and seeking professional assistance when needed will help you manage your Hong Kong tax obligations effectively and avoid costly penalties.
Key Takeaways
- Monitor eTAX Regularly: Check your Message Box at least weekly and enable email notifications to ensure you never miss important communications
- Respect the 1-Month Rule: Most IRD communications require responses within 1 month—mark deadlines clearly and work backwards to create action plans
- Leverage Electronic Filing: Filing tax returns electronically through eTAX grants an automatic 1-month extension for individuals
- Maintain 7-Year Records: Keep all business and tax records for at least 7 years in readable, retrievable formats to support your tax positions
- Understand “Pay First, Argue Later”: You must generally pay assessed tax even when objecting, unless you successfully apply for a holdover
- Follow the Appeal Ladder: The structured process moves from objection (Section 64) to Board of Review (Sections 65-66) to courts—each with strict 1-month timeframes
- Prepare Detailed Objections: Written objections must include precise grounds and supporting evidence—vague complaints will be rejected
- Use Available Features: The enhanced 2024/25 eTAX platform allows upload of up to 5 documents (200MB total) and provides mobile access to all functions
- Seek Professional Help: Complex matters, assessments you wish to challenge, and appeals benefit significantly from professional tax representation
- Never Ignore Communications: All IRD notices require attention—ignoring them leads to escalating penalties, including fines up to HKD 10,000 plus additional tax of up to 3x the unpaid amount
Disclaimer: This article provides general information about Hong Kong tax procedures and should not be construed as professional tax advice. Tax laws and IRD procedures are subject to change. For specific guidance on your tax situation, consult with a qualified tax professional or contact the Inland Revenue Department directly.