Technical Seminar on Overview of Hong Kong's New Guidance on Transfer Pricing - DIPN 46

The seminar will provide an overview of the recent developments in the transfer pricing(TP) regime in Hong Kong. It will include discussions on how taxpayers in Hong Kong are affected by the recent developments and what taxpayers can do to defend their positions against challenge by the Hong Kong Inland Revenue Department.

Topics to be included in this seminar:
1. A high level overview of the TP regime in Hong Kong?

2. What happened in 2009?

• Issuance of DIPN 45 - "Relief from Double Taxation due to TP or Profit Reallocation Adjustments" in April 2009
• Court of Final Appeal's judgment in the Ngai Lik Electronics Company Limited vs Commissioner of Inland Revenue tax case
• Issuance of DIPN 46 - "TP Guidelines –Methodologies and Related Issues" in December 2009

3. What effect does it have?

4. What is in DIPN 46?

• Legal basis for making TP adjustments and penalty implications
• Acceptable TP methods
• TP documentation guidelines
• TP related tax avoidance
• TP for permanent establishments

5. How does it affect me and what can I do to defend my position in case of tax audit?

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