The Hong Kong Inland Revenue Department (IRD) has released Departmental Interpretation and Practice Notes (DIPNs) No. 58
with new transfer pricing filing examples for UK-based enterprises. Generally, the deadline for these filings is 12 months after the close of the annual accounting period. In addition, the new DIPN No. 59
clarifies how IRD interprets the arm’s-length principle and transfer pricing rules, and DIPN No. 60
discusses profit allocation principles for ‘permanent establishments’ in Hong Kong. Finally, DIPN No. 28
’s provisions relating to foreign tax deductions were revised to align with new provisions from last year’s Inland Revenue (Amendment) (No. 6) Ordinance 2018.
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