The Inland Revenue Department issued new Departmental Interpretation and Practice Notes

The Inland Revenue Department issued new Departmental Interpretation and Practice Notes

The Inland Revenue Department (“IRD”) issued the following Departmental Interpretation and Practice Notes (“DIPN”):

DIPN 58 – Transfer Pricing Documentation and Country-by-Country Reports

https://www.ird.gov.hk/eng/pdf/2019/dipn58.pdf

DIPN 59 – Transfer Pricing Between Associated Persons

https://www.ird.gov.hk/eng/pdf/2019/dipn59.pdf

DIPN 60 – Attribution of Profits to Permanent Establishments in Hong Kong

https://www.ird.gov.hk/eng/pdf/2019/dipn60.pdf

The Inland Revenue (Amendment) (No. 6) Ordinance 2018 has codified the transfer pricing rules and documentation requirements. DIPN Nos. 58, 59 and 60 have been issued to set out the Department’s interpretation and practice on the relevant rules and requirements, and the latest international standards relating to transfer pricing.

Transactions between associated persons or non-Hong Kong resident persons’ permanent establishments in Hong Kong, to which the transfer pricing-related provisions in the Inland Revenue (Amendment) (No. 6) Ordinance 2018 do not apply, should be dealt with in accordance with DIPN Nos. 45 and 46.