Hong Kong implements Country-by-Country Reporting Notification requirements

Jan 2019

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. 

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Jeff Yuan

Asia Pacific Transfer Pricing Services Leader, PwC China

Tel: +[86] (21) 2323 3495

Cecilia Lee

Partner, PwC Hong Kong

Tel: +[852] 2289 5690

Phillip Mak

Partner, PwC Hong Kong

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Peter Brewin

Partner, PwC Hong Kong

Tel: +[852] 2289 3650

Wengee Poon

Partner, PwC Hong Kong

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Ali Tse

Partner, PwC Hong Kong

Tel: +[852] 2289 3508

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