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-owned subsidiary in Mainland China (Company G). The two entities operated an import processing arrangement under which the Appellant would purchase raw materials from suppliers for sale to Company G and in turn purchase finished products from Company...