Hong Kong has published a guidance page on Transfer Pricing Documentation – Master File and Local File, which provides an overview of the requirements, the relevant thresholds/exemptions, the required content, the timing for preparation, etc. For accounting periods beginning on or after 1 April 2018, a Hong Kong entity must prepare a master file and a local file no later than 9 months after the end of its accounting period, subject to the exemption thresholds. Whether a master file and local file have to be prepared must be declared in the profits tax return and supplementary form S2. If required, the master file and the local file should be ready for submission upon request by the assessor.
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