Hong Kong based companies with offshore claims need to anticipate the impact of greater reporting requirement in light of the OECD’s Base Erosion Profit Shifting (“BEPS”) initiatives. Conflicts with transfer pricing (“TP”) and possible permanent establishment (“PE”) challenges must, more than ever, be carefully managed.  While there may be a legitimate basis to make an offshore claim, there may be increasing questions from tax authorities overseas, companies should carefully consider how this may coincide with their TP policies and possible consequences from a wider group perspective.