Seminar on DIPNs 58, 59 and 60:

New Guidance on Hong Kong Transfer Pricing Matters

21 August 2019 | Hong Kong

The Inland Revenue Department (IRD) released Departmental Interpretation and Practice Notes (DIPNs) no. 58, 59 and 60 on 19 July 2019, providing guidance to taxpayers on a number of transfer pricing issues contained in the Inland Revenue (Amendment) (No. 6) Ordinance 2018 (IRO).

The purpose of the DIPNs is to provide guidance in relation to the 3-tier approach to TP documentation, application of transfer pricing principles between associated persons and attribution of profits to Permanent Establishments (PEs) in Hong Kong.

Some of the key issues covered in the DIPNs include:

  • Understanding Master File/Local File requirements in HK and threshold levels for preparation;
  • Country-by-Country reporting obligations, including clarification of secondary filing requirements in HK;
  • Application of the transfer pricing principles as outlined in the IRO, including the operation of the domestic exemptions and grandfathering provisions;
  • Practical considerations when preparing a transfer pricing analysis;
  • Attribution of profits to PEs and the application of the Authorized OECD Approach (AOA) in HK.

To help you understand the new guidelines provided in the DIPNs and how they may impact you, Deloitte China is delighted to invite you to participate in one of our seminars which will be conducted in Cantonese or English. 

Event details

Date: 21 August 2019 (Wednesday)

Venue: 6/F, 12 Taikoo Wan Road, Taikoo Shing, Hong Kong

Time: 1:30 - 3:00 pm (Cantonese session)
           4:00 - 5:30 pm (English session)
           *Please select ONE of language/session above

Duration: 1 hour and 30 mins

Fee: Complementary to our valued clients

Registration & Enquiries

RSVP to join the seminar

A registration confirmation will be sent out no later than Wednesday, 14 August 2019.

Registration status:

Markets and Global Network

Ms. Wandy Luk

Tel: (852) 2852 6331    



Seminar content: 

Tax and Business Advisory Services

Ms. Evon Chik

Tel: (852) 2852 1269