Hong Kong is the latest tax jurisdiction to have its own transfer pricing law.

“Large” corporations in Hong Kong are expected to prepare transfer pricing documentation (i.e.., Transfer Pricing Master File, Local File and Country-by-Country Report). The IRD is also empowered to impose transfer pricing adjustments to Hong Kong taxpayers.

Cross-border Related party transactions has been the focus of the Hong Kong Inland Revenue Department since the enactment of transfer pricing rules into the Inland Revenue Ordinance. Companies should document their transfer pricing policies for their Hong Kong operations, meanwhile assess their risks through the exercise.

Our international tax and transfer pricing team can help you assess your global transfer pricing tax risk and advise on the tax efficiencies of group arrangement.

We can assist you on the following services:

  • Annual Transfer Pricing documentation on Master File and Local File
  • Benchmarking report on specified transaction and advisory for tax investigation and management reporting purposes
  • Country-by-Country Notification and Report filing in Hong Kong

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