In our August 2022 Issue of Newsletter, we will study three points for attention in the latest development of Hong Kong Transfer Pricing Documentation Requirements.3.   Timing Differences in Country-by-Country (CbC) NotificationAdditional procedures are still requested when the UPE / SPE submit its CbC Notification after the Hong Kong Constituent EntityIn Hong Kong, Taxpayers exceeding the threshold are generally required to

Timing Differences in Country-by-Country (CbC) Notification

In our August 2022 Issue of Newsletter, we will study three points for attention in the latest development of Hong Kong Transfer Pricing Documentation Requirements.2.   Revised Transfer Pricing Form IR1475 issued in November 2021The IRD is committed to revising Form IR1475 to align with OECD Guideline and taxpayers’ burden remain heavyDespite the fact that Form IR1475 is supposed to be

Revised Transfer Pricing Form IR1475 issued in November 2021

​In our August 2022 Issue of Newsletter, we will study three points for attention in the latest development of Hong Kong Transfer Pricing Documentation Requirements.1.  Form IR1475 - A Summary of Transfer Pricing Master File and Local FileTaxpayers are requested to submit Form IR1475 within one month from the IRD’s requestIn the Annual Meeting between Hong Kong Institute of Certified

Form IR1475 – A Summary of Transfer Pricing Master File and Local File

In the past, many corporations tend to disregard their Country-by-Country (“CbC”) compliance obligation. They consider that CbC return does not offer much help to the IRD in reviewing the tax position, and thus tend to believe that the IRD would not check whether a taxpayer has already reached the threshold of CbC filing and whether they have missed the due

IRD Warning on late Country-by-Country Return Notification

The Hong Kong Inland Revenue Department (“IRD”) has formulated its procedures to review transfer pricing documentation. First round of compliance reviews is expected to commence in Year 2021.Standard form of “Transfer Pricing Documentation – Master File and Local File” (“Form IR1475”) will be used to gather high-level information of taxpayers’ transfer pricing policies before requesting the submission of Master File

Hong Kong Transfer Pricing Update

Hong Kong is one of the latest tax jurisdictions to codify its own transfer pricing law, with 2020 being the first year for some Hong Kong corporations to prepare transfer pricing documentation.Renowned for being one of the lowest tax rate jurisdictions, and for its conductive business environment, Hong Kong is a place in which multinational corporations (MNCs) tend to allocate

Hong Kong Codification of Transfer Pricing Law