Transfer Pricing Documentation

Other Information

Country by Country Reporting In Hong Kong

Under Hong Kong Transfer Pricing Law, a multinational enterprise group (MNE Group) is required...

Hong Kong Tax Treaty Network

Under Hong Kong Transfer Pricing Law, a multinational enterprise group (MNE Group) is required...

Hong Kong Withholding Tax Rates under DTA

Table: Withholding Tax Rates under Comprehensive Double Taxation Agreement /...

A Hong Kong entity of a group engaging in transactions with associated entities is required to prepare a Master File and a Local File, subject to certain exemptions. To be specific, if a Hong Kong company reaches the following Criteria (A) and (B), it is required to prepare a Master File and a Local File for submission to the Inland Revenue Department upon request:
Criteria (A): Based on size of business (any two out of three of the below)
Threshold (per financial year)
(i) Total annual revenue>HK$400 million
(ii) Total assets>HK$300 million
(iii) Employees>100
Criteria (B): Based on related party transactions (any one out of four of the below)
Threshold (per financial year)
(i) Transfers of properties
(excludes financial assets / intangibles)>HK$220 million
(ii) Transactions in financial assets>HK$110 million
(iii) Transfers of intangibles>HK$110 million
(iv) Any other transactions
(e.g., service income / royalty income)>HK$44 million

For details, please visit https://www.ird.gov.hk/eng/tax/bus_tp.htm or Connect with Us.

Other Information

Country by Country Reporting In Hong Kong

Under Hong Kong Transfer Pricing Law, a multinational enterprise group (MNE Group) is required...

Hong Kong Tax Treaty Network

Under Hong Kong Transfer Pricing Law, a multinational enterprise group (MNE Group) is required...

Hong Kong Withholding Tax Rates under DTA

Table: Withholding Tax Rates under Comprehensive Double Taxation Agreement /...