Guidance gets mixed reviews from Hong Kong taxpayers
December 10, 2009
The release of Hong Kong’s newest practice note on transfer pricing has been widely welcomed by taxpayers, but concerns have been raised over its lack of clarity.
Released last week,
Departmental Interpretation Practice Note (DIPN) 46 outlined guidelines establishing the tax authoritys interpretation and practices on methodologies and related issues.
DIPN 46 is a follow-up to DIPN 45 which dealt with the double taxation aspects of transfer pricing.

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