Hong Kong Transfer Pricing: Interest free and interest-bearing intra-group financing: taking action under the new Hong Kong TP Law

22 November 2019, Hong Kong

By invitation only  


The Hong Kong SAR government enacted the Inland Revenue (Amendment) (No. 6) Ordinance 2018 ("the BEPS and TP Ordinance") in July 2018 codifying transfer pricing ("TP") rules into Hong Kong's tax law. With the introduction of arm's length principle and the mechanism of TP adjustments arising from non-arm's length transactions, it is more important than ever to review the TP arrangements of Hong Kong entities to ensure your Group TP position is well protected.

In Hong Kong, it is typical to see group entities have various domestic and cross-border financing arrangements in place either for liquidity provision or investment purposes. These arrangements could often involve transactions incurred between Hong Kong entities and overseas investment vehicles (e.g. BVI SPVs) / operational companies or among Hong Kong entities with different tax positions that could give rise to potential TP implications in the context of the new Hong Kong TP law.

In this seminar, our TP professionals will discuss the typical scenarios of intra-group financing arrangements within Hong Kong or between Hong Kong and overseas tax jurisdictions and consider how these might be impacted by the implementation of the Hong Kong TP law. Our professionals will share insights on measures to be taken to protect the existing arrangements and establish a robust TP mechanism to mitigate potential TP risks. In addition, there will be discussions on planning for sustainable future arrangements and interplay of information disclosure requirements under the TP documentation rules.

Event details

Date:               22 November 2019 (Friday)

Time:              10.30am - 12.00 noon (10.15am registration) - English
                       2.30pm - 4.00pm (2.15pm registration) - Putonghua

Venue:            PwC Executive Conference Centre,
                       21/F, Edinburgh Tower, The Landmark,
                       15 Queen's Road, Central, Hong Kong

Fee:                Complimentary


For enquiries, please contact

Tracy Chan
Tel: +[852] 2289 3545

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