The Hong Kong Inland Revenue Department has issued Departmental Interpretation and Practice Notes (DIPN) Nos. 58, 59, and 60 to set out the Department’s interpretation and practice on transfer pricing rules and documentation requirements that were codified through Inland Revenue (Amendment) (No. 6) Ordinance 2018 ({News-2018-07-16/A/2-previous coverage}). DIPN 58 – Transfer Pricing Documentation and Country-by-Country Reports DIPN 58 covers the three-tiered approach to transfer pricing documentation that was implemented as part of the Ordinance. This includes Local and Master file requirements, which apply in relation to accounting periods beginning on or after 1 April 2018, and CbC reporting requirements, which...