Transfer pricing
Forvis Mazars' comments on Transfer Pricing issues
April 2020 - Hong Kong issued advance ruling on interpretation of permanent establishment
In February 2020, the Hong Kong Inland Revenue Department (“IRD”) published an advance ruling case on interpretation of Permanent Establishment (“PE”) in Hong Kong.
December 2019 - Transfer Pricing In Hong Kong - Departmental Interpretation and Practice Notes
Annual Review: Transfer Pricing 2019
Anthony Tam, Executive Director of Tax Advisory Services at Mazars in Hong Kong, has been featured in Financier Worldwide 2019 Transfer Pricing Annual Review. Anthony contributed the China chapter of the report, providing insight into key developments in the region.
January 2019 - Country-by-Country Reporting in Hong Kong
The Inland Revenue (Amendment) (No.6) Ordinance 2018 (the “Amendment Ordinance”) passed into law in July 2018, introduces statutory transfer pricing regime and implements various minimum standards under the Organisation for Economic Co-operation and Development (“OECD”)’s Base Erosion and Profit Shifting (“BEPS”) Action Plans. The Amendment Ordinance adopts the three-tier documentation structure, comprising a Master File, Local File and Country-by-Country Reporting (“CbCR”) recommended in the OECD BEPS Action Plan 13.
July 2018 - The Transfer Pricing and BEPS Legislation Passed in Hong Kong
The legislation to (1) introduce the statutory transfer pricing regime, and (2) implement the various minimum standards under the OECD’s Base Erosion and Profit Shifting (“BEPS”) Action Plans, Inland Revenue (Amendment) (No.6) Ordinance 2018 ( the “Bill”) was passed by the Legislative Council on 4 July 2018. Please refer to our February and March 2018 Hong Kong Tax News on the background leading to the then draft legislation (the “Draft Bill”).