The Hong Kong Inland Revenue Department has issued Departmental Interpretation and Practice Notes (DIPN) Nos. 58, 59, and 60 to set out the Department’s interpretation and practice on transfer pricing rules and documentation requirements that were codified through Inland Revenue (Amendment) (No. 6) Ordinance 2018 ({News-2018-07-16/A/2-previous coverage}).
DIPN 58 – Transfer Pricing Documentation and Country-by-Country Reports
DIPN 58 covers the three-tiered approach to transfer pricing do…