Transfer Pricing and Treaties
Specialist transfer pricing and double taxation treaty advisory in Hong Kong, covering documentation, APAs, CDTA benefits, and BEPS compliance.
Our Transfer Pricing and Treaties Services
Transfer Pricing Policy and Documentation
- Designing transfer pricing policies that reflect the arm's length principle and commercial substance
- Preparing master files, local files, and Country-by-Country Reports in compliance with Hong Kong requirements
- Reviewing and updating existing transfer pricing documentation to address regulatory changes
- Benchmarking intercompany transactions using appropriate methodologies and comparable data
- Advising on documentation standards across multiple Asia-Pacific jurisdictions
Advance Pricing Arrangements
- Advising on the suitability and strategy for unilateral, bilateral, and multilateral APA applications
- Preparing and filing APA applications with the Inland Revenue Department
- Managing the APA negotiation process with Hong Kong and foreign competent authorities
- Advising on APA renewals and modifications in response to changing business circumstances
- Structuring rollback provisions to resolve prior-year transfer pricing positions
Hong Kong Transfer Pricing Rules
- Advising on the scope and application of the Inland Revenue (Amendment) (No. 6) Ordinance
- Analysing related-party transactions for compliance with Hong Kong's arm's length standard
- Advising on the transfer pricing implications of business restructurings involving Hong Kong entities
- Managing the interaction between transfer pricing rules and Hong Kong's territorial source principle
- Advising on penalties and safe harbour provisions under Hong Kong transfer pricing legislation
Comprehensive Double Taxation Agreement Network
- Identifying treaty benefits available under Hong Kong's expanding CDTA network
- Advising on eligibility for reduced withholding tax rates on dividends, interest, and royalties
- Structuring operations to qualify for treaty benefits while meeting substance and beneficial ownership requirements
- Advising on limitation on benefits provisions and principal purpose test implications
- Monitoring new CDTAs and protocol amendments for planning opportunities
Mutual Agreement Procedures
- Assisting with MAP applications where double taxation arises from transfer pricing adjustments
- Coordinating with competent authorities in Hong Kong and treaty partner jurisdictions
- Advising on the interaction between MAP and domestic dispute resolution processes
- Managing the timeline and procedural requirements of MAP cases
- Advising on corresponding adjustments and the elimination of double taxation
Country-by-Country Reporting
- Advising on CbCR notification and filing obligations for Hong Kong constituent entities
- Preparing Country-by-Country Reports in compliance with Hong Kong and OECD standards
- Managing the exchange of CbCR information with foreign tax authorities
- Advising on the implications of CbCR data for transfer pricing risk assessments
- Coordinating CbCR compliance across multiple jurisdictions within a multinational group
Our Approach
Technically Grounded Advisory
Commercially Practical Solutions
Coordinated Multi-Jurisdictional Approach
Dispute-Ready Documentation
