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 [email protected] |
James Yeo Transfer Pricing Manager, WTS Taxise [email protected] |
