Dec 2009 - DIPN 46 Transfer Pricing
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HK Tax Newsletter - DIPN 46
On 4 December 2009, the IRD released Departmental Interpretation and Practice Notes No. 46, Transfer Pricing Guidelines – Methodologies and Related Issues (DIPN 46). For the first time, the IRD shows its views on application of transfer pricing principles and methodologies within the tax framework of Hong Kong.
For the first time, the IRD shows its views on application of transfer pricing principles and methodologies within the tax framework of Hong Kong. The purpose of DIPN 46 is to illustrate how the IRD applies transfer pricing principles in situations where transfer pricing issues arise. It sets out a framework for the IRD to follow when establishing the arm’s length prices of a taxpayer’s related party transactions.
