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Transfer Pricing

Transfer Pricing in Hong Kong: An Overview

Transfer pricing refers to the pricing of transactions between associated entities within a multinational enterprise (MNE). Hong Kong has implemented a robust transfer pricing regulatory regime to ensure that these transactions are priced at "arm's length," meaning the price would be similar to what independent third parties would agree upon under similar circumstances. This is aimed at preventing tax avoidance by shifting profits to low-tax jurisdictions.

Here are some key points about transfer pricing in Hong Kong:

Compliance Requirements:

  • Arm's Length Principle: All intra-group transactions in Hong Kong must be priced at arm's length.

  • Transfer Pricing Documentation: MNEs with Hong Kong entities exceeding certain thresholds (e.g., exceeding HKD 220 million in tangibles transfer) must prepare and maintain transfer pricing documentation, including a Master File, Local File, and Country-by-Country Report.

  • Penalties: Non-compliance with transfer pricing regulations can lead to penalties, including tax adjustments and fines.

Recent Developments:

  • Increased scrutiny by the Inland Revenue Department (IRD) with more transfer pricing audits and reviews expected.

  • Focus on intangible property transactions involving intellectual property (IP) and digital services.

  • Alignment with international standards and OECD BEPS guidelines.

Additional Resources:

Transfer Pricing Documentation in Hong Kong

Hong Kong adheres to a three-tiered standardized approach to transfer pricing documentation, similar to the OECD guidelines. This requires preparation of:

1. Master File: This document provides a broad overview of the MNE's global business operations, including:

  • Organizational structure: A diagram illustrating the relationships between associated entities.

  • Business activities: Descriptions of the core functions and risks performed by each entity.

  • Intangible property: Information on the MNE's intangible assets and how they are exploited.

  • Transfer pricing policies: The overall approach used to set prices for controlled transactions.

2. Local File: This document focuses on specific controlled transactions conducted by the Hong Kong entity, including:

  • Transaction details: Descriptions of the goods, services, or intangibles transferred.

  • Transfer pricing method: The specific method used to determine the arm's length price (e.g., comparable uncontrolled transaction (CUT) method, profit split method).

  • Comparability analysis: Supporting data and justification for the chosen transfer pricing method.

  • Financial information: Relevant financial data for the Hong Kong entity and comparable companies.

3. Country-by-Country Report (CbC Report): This report provides high-level information on the MNE's global allocation of income and taxes, including:

  • Revenue, profit, and taxes: Aggregate data for each jurisdiction where the MNE operates.

  • Employee headcount: Number of employees in each jurisdiction.

  • Tangible assets: Location and book value of tangible assets in each jurisdiction.

Thresholds for Documentation:

Hong Kong has separate thresholds for preparing the Master File and Local File:

  • Master File: Required for all MNEs with controlled transactions exceeding HKD 220 million in a tax year.

  • Local File: Required for any Hong Kong entity that has controlled transactions exceeding HKD 20 million in a tax year.


Certain categories of controlled transactions are exempt from the documentation requirements, such as:

  • Routine low-value transactions

  • Financing transactions with associated financial institutions

  • Transactions between companies in the same tax group

Benefits of Proper Documentation:

Maintaining proper transfer pricing documentation can offer several benefits for MNEs operating in Hong Kong, including:

  • Reduced risk of tax audits and penalties

  • Demonstrates compliance with transfer pricing regulations

  • Provides a clear and defensible transfer pricing methodology

  • Facilitates efficient communication with the IRD

Seek Professional Advice:

Transfer pricing can be a complex area, and it's essential to seek professional advice from tax advisors or transfer pricing specialists to ensure compliance with Hong Kong's regulations and minimize tax risks.

Seeking Bestar's Professional Advice on Transfer Pricing in Hong Kong

Transfer pricing can be a intricate web of regulations and calculations, and proper guidance is crucial for ensuring compliance and minimizing tax risks in Hong Kong. Here's how Bestar can assist you:

Expertise and Experience:

  • Seasoned Tax Advisors: Bestar boasts a team of experienced tax advisors well-versed in the intricacies of Hong Kong's transfer pricing regulations. We stay updated on the latest developments and interpretations, ensuring your approach aligns with current requirements.

  • Dedicated Transfer Pricing Specialists: Complexities often arise with intangible property and digital transactions. Bestar's transfer pricing specialists possess in-depth knowledge and practical experience in handling these nuances, ensuring accurate and defensible pricing strategies.

Comprehensive Support:

  • Tailored Solutions: No two businesses are alike. Bestar recognizes this and takes a personalized approach, understanding your specific business model, transactions, and risk profile to craft a customized transfer pricing solution that optimizes your tax efficiency.

  • Documentation Preparation: From Master Files and Local Files to Country-by-Country Reports, Bestar's team can handle the preparation and maintenance of all required documentation, ensuring accuracy, completeness, and adherence to the prescribed formats.

  • Audit Defense: In case of a tax audit, Bestar's professionals can represent you with the Inland Revenue Department (IRD), providing clear explanations, justifications, and supporting evidence for your transfer pricing practices.

Benefits of Choosing Bestar:

  • Reduced Tax Risks: With Bestar's guidance, you can minimize the risk of tax adjustments and penalties, ensuring peace of mind and maximizing your bottom line.

  • Enhanced Compliance: Our expertise helps you navigate the complexities of Hong Kong's transfer pricing regulations, ensuring you stay compliant and avoid potential legal issues.

  • Efficient Resource Allocation: By optimizing your transfer pricing strategies, Bestar can help you allocate resources effectively, leading to improved financial performance.

  • Focus on Core Business: With Bestar handling your transfer pricing matters, you can free up your valuable time and resources to focus on your core business operations and driving growth.

Taking the Next Step:

Ready to leverage Bestar's expertise for your transfer pricing needs? You can easily reach out to our team through our website, phone, or email. Remember, seeking professional advice can significantly reduce your tax risks and ensure a smooth sailing experience in the ever-evolving landscape of Hong Kong's transfer pricing regulations.

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