Transfer Pricing Tax Alert : 9 January 2012
Our commentary
Contacts for financial services
Contacts for other industries
When the APA measures are finalised, it will mark the first time Hong Kong recognises APA. As many taxpayers may enter into intercompany transactions are relatively large and complex, it may be time to evaluate whether a BAPA is an appropriate tool to improve certainty with respect to tax treatment.
As the BAPA application and negotiation process can often involve substantial information being collected and analysed both by the taxpayer and the relevant tax authorities, you may wish to begin evaluating your options prior to the roll out of the Hong Kong APA programme.
Additionally, if there are any comments or feedback on the APA programme for the HKIRD, please feel free to contact us and we will ensure they are reflected to the HKIRD.
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