Hong Kong’s plan to legislate BEPS: what to expect

Stefano Mariani and Calvin Ng recently contributed an article to MNE Tax on what to expect from upcoming Hong Kong tax legislation.

The Hong Kong government on July 31 published its conclusions on a consultation exercise responding to the 2015 OECD/G20 base erosion profit shifting (BEPS) package, making it clear that the territory’s stance as the easy and light-touch structuring jurisdiction of the 1980s will soon be over.

Key features of the announcement covered, among other things, transfer pricing rules, advance pricing arrangements, related party transactions, and country-by-country reports.

As perhaps the most ambitious tax law reform project in Hong Kong’s history since the Third Inland Revenue Ordinance Review Committee in the 1970s, the implementation of BEPS in Hong Kong should be a timely reminder that economic globalisation will inevitably lead to calls for greater fiscal harmonisation.

Practitioners will need to be nimble, responsive, and creative in assisting their clients in responding to new challenges occasioned by city’s integration with global tax networks.

Please click here to read the article.