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Hong Kong Profits Tax Return Deadlines: N, D and M Codes, the Block Extension and E-Filing

By Di Ma, Project Manager 22 OCT 2026 · 5 MIN READ

Every year on the first working day of April, the Inland Revenue Department sends out profits tax returns in bulk. The question every director then asks is simple — when is ours due? — and the answer is not one date. It depends on when the company's accounting year ends, whether it has a tax representative, whether it files on paper or electronically, and, for some companies, whether it made a loss.

Here is how it works, with the actual dates for the 2025/26 year of assessment taken from the IRD's own circulars to tax representatives.

The starting point: one month, unless extended

A profits tax return has to be filed by the date printed on it, which is normally one month from the date of issue. For the returns issued on 1 April 2026, that meant early May. Most companies, however, cannot have audited accounts ready a month after receiving the return — especially if their year ended only weeks before — so the IRD runs a Block Extension Scheme for taxpayers who have a tax representative (usually their accountant or tax adviser, authorised by the company in writing).

Under the scheme the due date depends on the company's accounting date code, which is simply a label for when its financial year ends.

2025/26 due dates by accounting year end

Source: IRD circular letters Block Extension Scheme for Lodgement of 2025/26 Tax Returns and its 14 July 2026 update for the D code.

The e-filing month: an option, not the default

The IRD gives one further month to companies that file their profits tax return electronically through its Business Tax Portal — but for most companies only on application, and the application must reach the IRD at least seven working days before the return is otherwise due. The month runs from the day after the paper due date. If the extra month is requested and the company then files on paper, the extension is treated as void and penalties can follow.

That is why we treat the paper date as the real deadline. The e-filing month is a useful safety margin when it has been arranged in advance; it is not something to discover a week before the paper date has passed.

(Very large multinational groups — "Part 4AA entities", with consolidated revenue of EUR 750 million or more — must e-file and get the extra month automatically. That does not concern most small and medium-sized companies.)

Loss-making companies with a March year end

To let practitioners concentrate on profit cases first, M-code companies that made an allowable loss can have until 1 February 2027. It is not automatic: the tax representative has to send the IRD a list of the loss cases, which for 2025/26 had to arrive by 2 November 2026 (individual late requests up to 16 November). And the return must in the end show a loss — if it reports a profit instead, the further extension is void.

A company's first profits tax return

A newly incorporated company does not get a return in its first April. The IRD generally issues the first profits tax return about 18 months after incorporation, and a first return can be filed within three months of its date of issue — no extension application needed. Separately, a company that is chargeable to tax but has not received a return must notify the IRD within four months after the end of its basis period.

What happens if the deadline is missed

The IRD can issue an estimated assessment — tax based on its own estimate of your profits — and can take penalty action under sections 80 and 82A of the Inland Revenue Ordinance. Further extensions beyond the block extension dates are granted only in exceptional cases, must be requested in writing at least 14 days before the date, and need evidence. The IRD's own words: companies that file late persistently are "almost certain to face penalty action".

What you need before the return can be filed

• Audited financial statements for the accounting year — every Hong Kong company needs them (see what your auditor will ask for).
• A tax computation that reconciles the accounting profit to the assessable profit.
• The supplementary forms that apply to the company, filed with the return.
• All amounts in Hong Kong dollars, without cents — financial statements kept in another currency have to be converted for the return.

Most late returns are not late because of the return itself. They are late because the books were written up at year-end and the audit started late. Books that are kept current all year move everything that follows earlier.

How Certanta keeps track

For Certanta clients the deadlines are not a calendar entry someone has to remember. The client portal lists the dates that apply to the company — the profits tax return under the IRD's dates for its accounting date code, the accounts due to shareholders, and the other statutory dates — and marks each one off when it has been filed. The return itself is prepared from books that have been kept current and checked by a bookkeeper all year; the company signs and files it.

Monthly bookkeeping plans include the profits tax return; it can also be added to an annual package — see pricing.

Frequently asked questions

This article summarises the Inland Revenue Department's published arrangements for the 2025/26 year of assessment as at 22 October 2026. It is general information, not tax advice; the date printed on your own return and any notice from the IRD always take precedence. We will update it when the IRD publishes the 2026/27 arrangements.