On 04 July 2018 the Inland Revenue Department (IRD) passed Hong
Kong's final Inland Revenue (Amendment) (No. 6) Bill 2017, (the
Amendment Bill). This Amendment Bill (became a law on 13 July 2018)
specified the documentary requirements from a Transfer pricing
perspective and also introduced measures to address various
recommendations under BEPS Action Plans. With the amendment in the
Ordinance 2018, Hong Kong has implemented the minimum standards for
Base Erosion and Profit Shifting (BEPS) package and formally
introduced a Transfer Pricing (TP) regulatory regime and
documentation requirement into Hong Kong tax law.
This article is intended to lay down the key elements of the new
TP regime in Hong Kong and our comments on the areas that
companies' management ought to deliberate to adhere in terms of
the regulatory TP compliance.
