Under Hong Kong Transfer Pricing Law, a multinational enterprise group (MNE Group) is required to file a Country-by-Country (CbC) Reporting in relation to an accounting period where:

Ø the consolidated group revenue for the preceding accounting period is at least EUR750 million (or HK$6.8 billion); and

Ø the group has constituent entities or operations in two or more jurisdictions.

Key requirements of the CbC Reporting

1. MNE Group must submit a CbC Notification to the Inland Revenue Department (IRD) within 3 months after the end of the relevant accounting period;

2. MNE Group must file a CbC Return within 12 months after the end of the relevant accounting period or the date specified in the assessor’s notice, whichever is the earlier.

Our team can assist you with the following services

ü Submit the Form IR1465 and appoint our team as Service Provider (engaged by the Reporting Entity under Section 56M of the Inland Revenue Ordinance)

ü Access the CbC Reporting Portal to manage your CbC Reporting affairs

ü Submit CbC Notification for or on behalf of the Reporting Entity

ü Prepare and file a CbC Return for or on behalf of the Reporting Entity

Penalties are provided in respect of matters such as failing to file CbC Returns and providing misleading, false or inaccurate information in CbC Returns.