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New Hong Kong Transfer Pricing Rules

On 29 December 2017, the Hong Kong SAR Government (“the Government”) introduced draft legislation, the Inland Revenue (Amendment) (No. 6) Bill 2017 (“the Bill”), to implement key actions arising from the base erosion and profit shifting (“BEPS”) agenda of the Organisation for Economic Co-operation and Development (“OECD”). When enacted, the Bill will codify transfer pricing rules into Hong Kong’s domestic tax law, introduce mandatory transfer pricing documentation requirements, formalise the advance pricing arrangement (“APA”) regime, and impose a penalty regime with civil and criminal sanctions.