Hong Kong’s Inland Revenue Department (IRD) recently issued a revised practice note (Revised DIPN 31) which explains that the IRD is now required to spontaneously furnish to the tax authorities of certain foreign jurisdictions any of the following four categories of tax rulings issued by the IRD:
(i) Rulings related to preferential tax regimes1
(ii) Unilateral Advance Pricing Arrangements and any other cross-border unilateral rulings in respect of transfer pricing
(iii) Permanent establishment (PE)…