Transfer Pricing Seminar | KPMG | CN
Share with your friends

Transfer Pricing Seminar – The Future of Transfer Pricing in Hong Kong upon Introduction of the BEPS Bill

KPMG Office, 23rd Floor, Hysan Place, 500 Hennessy Road, Causeway Bay, Hong Kong

15 January 2018 - 16 January 2018, 20:45 - 11:00, HKST

On 29 December 2017, the Inland Revenue (Amendment) (No. 6) Bill 2017 (BEPS bill) was gazetted (click here), proposing to introduce a comprehensive transfer pricing regime and anti-BEPS measures to Hong Kong. The BEPS bill marks a significant step up in Hong Kong’s transfer pricing enforcement regulation.

The Hong Kong government proposes fundamental transfer pricing rules which empower the Inland Revenue Department (IRD) to adjust the profits or losses of an enterprise if its related-party transactions are not conducted at arm’s length.

The introduction of the mandatory documentation requirements based on the three-tiered approach of Country-by-Country (CbCR) Reporting, Master File and Local File remains the most significant proposal since the release of the Consultation Report on Measure to Counter BEPS back in July 2017. The BEPS bill also converts the Advance Pricing Arrangement (APA) programme into a formal mechanism for taxpayers to obtain certainty on their transfer pricing matters.

During this seminar, we will analyse the impact of the BEPS bill to taxpayers in Hong Kong; in particular, we will cover the following topics:

  • Key elements of the BEPS bill;
  • Compliance obligations in terms of the three-tiered documentation requirements (i.e. Local File, Master File,  Country-By-Country (CbC) Reporting) and the IRD’s information collection powers;
  • The introduction of “permanent establishment” definition and its impacts
  • The transfer pricing rules on intellectual properties
  • The potential challenges to the source concepts 

The above topics would be illustrated by different types of case sharing across different industries to demonstrate what taxpayers would be facing under the BEPS environment and what they can do in light of the new challenges.


Please read the Hong Kong Tax Alert to find out more insights from KPMG on this topic


Connect with us

  English Session Cantonese Session
Date Monday, 15 January 2018 Tuesday, 16 January 2018
Time 8:45am – 9:00am (Registration)
9:00am – 11:00am (Seminar)
Veune KPMG Office
23rd Floor, Hysan Place
500 Hennessy Road
Causeway Bay, Hong Kong
Language English Cantonese

Should you have any queries, please do not hesitate to contact Phoebe Tsang on +852 3927 5624.