Hong Kong formally introduced a transfer pricing regulatory regime and transfer pricing documentation requirements into its tax legislation through the enactment of Inland Revenue (Amendment) (No. 6) Ordinance 2018 on 13 July 2018. This includes a legislative framework for Hong Kong to implement the Country-by-Country Reporting (“CbCR”) and Notification requirements effective from accounting periods beginning on or after 1 January 2018. The first CbCR Notification deadline is 31 March 2019 for Hong Kong entities with an Ultimate Parent Entity (“UPE”) that has a December financial year-end (or 3 months after the UPE year-end for other financial year ends). Details of the CbCR Notification requirements - the what, who, when and how - are provided below.