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20200928 Latest development of transfer pricing related tax controversy issues in Hong Kong
Description
The Inland Revenue (Amendment) (No. 6) Ordinance 2018 (the BEPS and TP Ordinance) was gazetted to codify TP rules in Hong Kong. With the formal introduction of the TP regulatory regime into Hong Kong tax legislation, the Inland Revenue Department (“IRD”) is following the global trend and taking a more aggressive approach on reviewing TP issues in cross-border intercompany transactions. TP-related tax disputes became one of the major tax controversy areas and the difficulties in resolving TP-related disputes with the IRD has been heighten. On the positive side, using TP methodology to resolve prolonged and comprehensive tax disputes cases become more receptive and acceptable by the IRD.
In view of this, we will share with you the below insights:
• Recap of the introduction of the TP legislation in Hong Kong
• Latest development of TP-related tax controversy issues
• How to resolve TP-related tax disputes
• How to use TP methodology to resolve tax audits
• Precaution measures to prevent potential TP-related tax disputes
• Real life case studies