The Hong Kong Inland Revenue Department (IRD) has released Departmental Interpretation and Practice Notes (DIPNs) Nos. 58, 59, and 60 and an updated version of DIPN No. 28 related to transfer pricing (TP Guidelines). DIPN No. 58
provides detailed explanations on transfer pricing documentation and country-by-country reports. DIPN No. 59
provides guidance on the arm’s-length principle and transfer pricing rules. DIPN No. 60
discusses how to ascertain profits attributable to a permanent establishment. DIPN No. 28
was updated to set out IRD’s interpretation and practice on the provisions relating to foreign tax deduction after the enactment of the Inland Revenue (Amendment) (No. 6) Ordinance 2018.
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