Transfer pricing in Hong Kong is changing post DIPN 46
April 14, 2010
Jacqueline Shek and Dawn Quek of Baker & McKenzie Hong Kong and Glenn DeSouza of TP Management Consulting in Shanghai evaluate some of the unusual aspects of departmental interpretation and practice note number 46 and assess its implications for companies operating in Hong Kong.
On December 4 2009, the Hong Kong Inland Revenue Department (IRD) issued its departmental interpretation and practice notes number 46 (DIPN 46), titled Transfer Pricing Guidelines – Methodologies and Related Issues. This signals that Hong Kong has joined other developed countries by starting to focus on transfer pricing issues for cross-borders transactions.
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