Hong Kong TP documentation and CbCR

While the HK DIPNs are largely consistent with OECD guidelines, it is worth noting the specific guidance around the use of TP methods, substance over form recharacterisation and the adoption of the AOA for PEs, which not all countries across Asia have adopted.


For further inquiries regarding this alert, please contact:

Sam Sim
Co-Founder and Senior Of Counsel, WTS Taxise
James Yeo
Transfer Pricing Manager, WTS Taxise