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Hong Kong's transfer pricing (TP) regime has undergone significant developments since the introduction of statutory TP rules in 2018. As the Inland Revenue Department (IRD) continues to strengthen its scrutiny of related-party transactions, businesses face increasing expectations to ensure that their intercompany arrangements comply with the arm's-length principle.
Hong Kong’s TP rules are not limited to cross-border taxable transactions. They may also apply to offshore transactions and other related-party dealings where a potential Hong Kong tax advantage arises. The regime covers a broad range of controlled transactions, including service arrangements, trading activities, financing arrangements, intellectual property transactions and business restructurings.
As businesses grow and expand internationally, establishing commercially sound and tax-efficient TP policies while effectively managing associated risks becomes increasingly important. A robust TP framework can support business operations, minimise the risk of tax disputes and provide greater certainty across jurisdictions.
Where required under Hong Kong's TP documentation rules, documentation is more than a compliance exercise. It provides important contemporaneous evidence that related-party transactions have been conducted on an arm's-length basis and serves as a key line of defence in the event of an IRD enquiry or TP audit.
Our experienced TP specialists help businesses navigate Hong Kong's evolving regulatory landscape, assess compliance obligations, identify planning opportunities and prepare defensible TP documentation. We provide practical, tailored solutions that align commercial objectives with effective tax risk management.
How We can Help
Our transfer pricing services include:
| ✅ | TP compliance and documentation: Comprehensive TP compliance support, including the preparation of Master Files and Local Files. |
| ✅ | Operational Transfer Pricing: TP model design, policy development, operational support and implementation of governance processes. |
| ✅ | TP Risk Assessment and Audit Defence: TP health checks, identification of potential risk exposures and preparation of audit defence documentation. |
| ✅ | TP Audits and Dispute Resolution: Assistance with TP audits, tax controversies and dispute resolution matters. |
| ✅ | Advance Pricing Arrangements (APAs): Preparation and negotiation of unilateral, bilateral and multilateral APAs with relevant tax authorities. |
| ✅ | Country-by-Country Reporting (CbCR): Support in managing CbCR requirements and ensuring compliance with applicable reporting obligations. |
Our specialists
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