Imagine receiving an audit notice from Hong Kong’s Inland Revenue Department (IRD) and realizing you can’t locate crucial tax documents from three years ago. With Hong Kong’s digital tax administration evolving rapidly and the IRD launching enhanced eTAX portals in July 2025, proper archiving and retrieval of electronic tax filings has become more critical than ever. This comprehensive guide explains how to effectively manage your eTAX records to ensure full compliance with Hong Kong’s stringent tax laws and prepare for potential audits with confidence.

Understanding Hong Kong’s Legal Record Retention Requirements

Section 51C: The Legal Foundation of Record Keeping

Section 51C of the Inland Revenue Ordinance establishes the bedrock requirements for business record keeping in Hong Kong. Under this provision, every person carrying on a trade, profession, or business must keep sufficient business records—in either English or Chinese—to enable their assessable profits to be accurately determined. These records must be retained for a minimum of seven years from the date of the transactions to which they relate.

What Records Must Be Retained?

The IRD’s comprehensive record-keeping requirements extend beyond simple tax returns to encompass a full range of financial documentation:

• Income statements reflecting the company’s revenue, expenses, and profitability
• Cash flow statements reporting cash inflows and outflows
• Asset and liability records including balance sheets
• Daily transaction records of all sums of money received and spent
• Sales and purchase records with corresponding vouchers and receipts
• Service provision records documenting business activities
• Tax returns and assessments filed through eTAX or paper submissions
• Supporting documentation for deductions, allowances, and claims

The IRD’s Back Assessment Powers and Audit Timeline

Understanding Back Assessment Periods

The IRD operates under an “assess first, audit later” approach, meaning that a notice of assessment or statement of loss is typically issued after initial processing of the tax return. However, the Department retains the power to conduct post-assessment investigations or field audits at a later date, either based on identified risk areas or through computerised random selection procedures.

The timeframes within which the IRD can raise additional assessments are crucial for understanding your record retention obligations:

The New eTAX Portal System: July 2025 Launch

Three Integrated Portals for Comprehensive Tax Management

In July 2025, the Inland Revenue Department launched a significantly upgraded eTAX infrastructure consisting of three specialized portals designed to serve different user groups:

• Individual Tax Portal (ITP): Provides a centralized platform for individual taxpayers to manage personal tax matters including tax return filing, personal particulars updates, viewing of tax positions, access to historical filing data, and management of payment records.
• Business Tax Portal (BTP): Specifically designed for businesses to handle corporate tax matters and compliance obligations electronically, including profits tax return filing, business registration, employer’s returns submission, and comprehensive access to corporate filing history.
• Tax Representative Portal (TRP): Caters to tax service agents, including tax representatives, company secretaries, and other tax service providers, enabling professionals to manage multiple client accounts efficiently.

Enhanced Features for Record Management

The 2025 portal upgrade introduced several significant improvements for archiving and retrieving tax records:

• Responsive Design: Interface automatically adjusts to desktops, tablets, and mobile devices
• Pre-filled Deduction Data: Taxpayers can pre-save deduction details which are automatically populated in future returns
• Enhanced Document Upload: Users can upload up to 5 supporting documents with a total file size of up to 200MB directly through eTAX
• Expanded IR56 e-Filing: Employers can upload up to 5,000 records in a single submission
• 24/7 Records Access: Complete filing history, assessments, and payment records accessible anytime
• Real-Time E-Alerts: Automated notifications for filing deadlines, assessment issuance, and payment due dates

Step-by-Step Guide: Accessing and Retrieving Past eTAX Filings

For Individual Taxpayers

1. Step 1: Log in to the Individual Tax Portal
   Visit the Individual Tax Portal through the GovHK eTAX gateway (www.gov.hk/etax) or download the “eTAX” mobile app. Log in using your Hong Kong Identity Card number and password, or authenticate via “iAM Smart” for enhanced security.
2. Step 2: Navigate to Your Tax Position
   Select “View Tax Position” from the main menu for an overview of your current tax status, including outstanding returns, recent assessments, and payment obligations.
3. Step 3: Access Filing History
   Click on “Filing History” or “Past Returns” to view a chronological list of all tax returns you have submitted through eTAX.
4. Step 4: Retrieve Specific Returns
   Select the specific year of assessment you wish to review. You can view the complete submitted return and download a PDF copy for your records.
5. Step 5: Review Assessment History
   Navigate to “Assessment History” to view all notices of assessment issued by the IRD, showing assessed income, tax payable, and payment status.
6. Step 6: Check Payment Records
   Access “Payment History” to view all tax payments made, including dates, amounts, and payment methods.

For Business Users

1. Step 1: Access the Business Tax Portal
   Log in using your Business Registration Number and designated user credentials. Company administrators can manage access for multiple authorized users.
2. Step 2: Select the Relevant Tax Type
   The Business Tax Portal handles multiple tax types including Profits Tax, Employer’s Returns (IR56 series), and Property Tax.
3. Step 3: Review Corporate Filing History
   Access complete records of all Profits Tax Returns filed, including the year of assessment, basis period, filed profits/losses, and submission dates.
4. Step 4: Retrieve Supporting Documentation
   If your business uploaded supporting documents (financial statements, tax computations), these remain accessible through the portal.
5. Step 5: Access Employer’s Return Records
   For IR56 series submissions, the portal maintains comprehensive records of all filed employer’s returns.

Best Practices for eTAX Record Archiving

Implement a Dual-Storage Strategy

While the eTAX portal provides excellent access to your filing history, prudent tax management requires maintaining your own independent archive. Download PDF copies of all filed returns, assessments, and payment confirmations immediately after submission and store them in a secure, backed-up location. This protects against potential system issues, changes to the portal, or circumstances where you need immediate access without internet connectivity.

Organize Records by Year of Assessment

Create a systematic filing structure organized by year of assessment rather than calendar year or filing date. For each year of assessment, maintain a complete folder containing:

• The original tax return (BIR60 for individuals, BIR51/52 for businesses)
• All supporting documentation and schedules
• The notice of assessment issued by the IRD
• Payment records and receipts
• Any correspondence with the IRD
• Amendment requests and revised assessments
• Holdover applications and decisions

Preparing for Tax Audits: Using Your eTAX Archive Effectively

Rapid Response Using eTAX Records

Your eTAX filing history becomes invaluable during an audit. Use the portal to quickly:

• Confirm what was filed: Download the exact returns as submitted for the years under audit
• Verify assessment amounts: Cross-reference the IRD’s records with your filed returns
• Review payment history: Demonstrate compliance with payment obligations
• Identify patterns: Compare multiple years of filings to understand year-on-year changes
• Locate digital submissions: Access any documents previously uploaded through the portal

Common Audit Focus Areas and Documentary Evidence

Common Pitfalls and How to Avoid Them

In Hong Kong’s increasingly digital tax environment, mastering eTAX record archiving and retrieval is no longer optional—it’s a fundamental compliance requirement. By implementing the strategies outlined in this guide, you can transform what might seem like an administrative burden into a strategic advantage. Proper record management not only ensures compliance with legal requirements but also positions you to respond confidently and efficiently to any IRD inquiries or audits. Remember, in tax matters, good records are your best defense and your strongest evidence.