Transformation of the Transfer Pricing Landscape

On 4 December 2009, the Inland Revenue Department released Departmental Interpretation Practice Note 46, “Transfer Pricing Guidelines on Methodologies and Related Issues”, and revised DIPN 21, “Locality of Profits”. Both Practice Notes provide clarification of the IRD’s views on transfer pricing and its approach in applying the provisions of the Inland Revenue Ordinance and relevant income tax treaties to establish whether related parties are observing the arm's length principle.