Hong Kong’s transfer pricing environment has changed significantly over the past three years. In 2009, Hong Kong’s Inland Revenue Department (IRD) released two Departmental Interpretation and Practice Notes (DIPN), namely DIPN 45 - Relief from double taxation due to transfer pricing or profit reallocation adjustments and DIPN 46 - Transfer pricing guidelines: Methodologies and related issues.
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ITR spoke to two US TP experts about the long-running dispute, with one arguing that the case highlights ‘weaknesses’ with the comparable uncontrolled transaction method
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