Transcription of Departmental Interpretation And Practice Notes - No
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Departmental Interpretation And Practice Notes - No
Inland Revenue Department Hong Kong Departmental Interpretation AND Practice Notes NO. 46 TRANSFER PRICING GUIDELINES -METHODOLOGIES AND RELATED ISSUES These Notes are issued for the information of taxpayers and their tax representatives. They contain the Department s Interpretation and practices in relation to the law as it stood at the date of publication. Taxpayers are reminded that their right of objection against the assessment and their right of appeal to the Commissioner, the Board of Review or the Court are not affected by the application of these Notes . LAU MAK Yee-ming, Alice Commissioner of Inland Revenue December 2009 Our web site : Departmental Interpretation AND Practice Notes No. 46 CONTENTS Paragraph Introduction Defining the issue 1 Associated enterprises Associated enterprises article 9 Participation in management, control or capital 13 Elimination of double taxation Double taxation and appropriate adjustment 15 Statutory provisions and case laws Provisions and case laws relevant to transfer pricing 17 Permanent establishments Attribution rules and profits of a permanent establishment 29 Arm s length principle The arm s length principle 36 Applying the arm s lengt
inland revenue department hong kong departmental interpretation and practice notes . no. 46 . transfer pricing guidelines - methodologies and related issues
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Attribution of Profits, ATTRIBUTION OF PROFITS TO PERMANENT ESTABLISHMENTS, Attribution, Permanent, Permanent establishments, LB&I International Practice Service Transaction Unit, Income Tax Act 2007, Taxation (International and Other Provisions) Act, Guidelines for requesting Mutual, Guidelines for requesting Mutual Agreement Procedure