Transfer pricing
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.
Mazars Transfer Pricing Services in Asia
Transfer pricing has grown to be one of the most prominent tax issues in the international arena, receiving priority attention from national governments as well as posing increasingly significant impacts on the operations of multinational enterprises. It focuses on the prices charged in related party transactions, including the internal transfer of tangible goods, intangible property, services, loan financing and leases, and affects every aspect of cross-border operations, and corporations’ worldwide tax burden.