Hong Kong Board of Review Publishes Decision Concerning Offshore Profits from China and a Claimed Downward Transfer Pricing Adjustment
The Hong Kong Inland Revenue Board of Review has published a decision concerning a taxpayer's claim that profits derived from transactions with China should be considered to have arisen offshore and a claim that transactions were not at arm's length and should result in a downward transfer pricing adjustment. The case involved a company incorporated in Hong Kong (the Appellant) and its wholly-…
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