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Hong Kong Publishes Ordinance Implementing BEPS Measures Including New Transfer Pricing Rules, Master and Local File Requirements, and CbC Reporting

16 July 2018

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Approved Changes

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Hong Kong

On 13 July 2018, the Hong Kong Government announced the publication of the Inland Revenue (Amendment) (No. 6) Ordinance 2018 in the Official Gazette, which primarily implements the minimum standards of the BEPS project. The main aspects of the Ordinance are summarized as follows: Transfer Pricing The OECD's transfer pricing rules are codified into the Inland Revenue Ordinance (IRO) so that both domestic and cross-border transactions between associated enterprises will be taxed on the basis that they are effected at arm's length. This includes reference to the 2017 OECD Transfer Pricing Guidelines and the OECD commentary on the associated enterprises...