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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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year