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China and Hong Kong transfer pricing documentation guide

March 29, 2010

Steven Tseng, Chi Cheng, Kari Pahlman and Nathan Richards of KPMG China outline the transfer pricing documentation guidelines in Hong Kong and China.

While Mainland China and Hong Kong are both part of the People’s Republic of China (PRC), they are governed by different legislative systems in accordance with the Hong Kong Basic Law (effective from the July 1 1997 return of Hong Kong to the PRC). Mainland China’s transfer pricing documentation requirements are the corporate income tax law (the CIT law) and its implementation rules (both effective from January 1 2008) while Hong Kong’s practices are ultimately derived from the Inland Revenue Ordinance (IRO).

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