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Hong Kong's
Inland Revenue Department
Other Resources
Transfer Pricing Guidelines - Methodologies and
Related Issues - Departmental Interpretation and Practice Notes No. 46
Provides the basis on which the Inland Revenue
Department ("IRD") will assess the arm's length nature of taxpayers' related
party transactions, make transfer pricing/profit reallocation adjustments
and determine whether a transfer pricing adjustment initiated by a party
other than the IRD.
December 4, 2009
Commissioner of Inland Revenue v. Datatronic Limited
The Hong Kong Court of Appeal issued a decision
that denies the availability of the “50:50 Concession” to a Hong Kong-based
seller of products manufactured in China by a related party.
July 15, 2009
Relief from Double Taxation due to Transfer Pricing or Profit Reallocation
Adjustments
The Hong Kong Inland Revenue Department issued a
practice note that describes how to claim double taxation relief under the
Hong Kong bilateral tax treaties for transfer pricing adjustments made by a
tax treaty partner.
April 30, 2009
Commissioner of Inland Revenue v. Ngai Lik Electronics Co. Ltd.
The High Court of Hong Kong's Court of Appeal
upheld a ruling that Ngai Lik Electronics violated Hong Kong's
anti-avoidance rules for 1991-1996 through a restructuring that moved
manufacturing operations from Hong Kong to mainland China, subcontracted the
Chinese manufacturing operation through several related British Virgin
Island entities, and incorporated a separate company in Bermuda to act as a
holding company for the group members.
October 15, 2008
Practice Note Clarifying the Permanent Establishment Threshold Under China
Tax Arrangement
The Hong Kong Special Administrative Region
(SAR) delivered a practice note that explains the permanent establishment
threshold under the SAR's 2006 double tax arrangement with the People's
Republic of China.
August 15, 2008 |
