Impact of international changes to Hong Kong and its reaction Rohit Narula
By: Narula, Rohit
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Material type: 
ArticlePublisher: 2018Subject(s): EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | PREVENCION | PROGRAMAS | APLICACION | FISCALIDAD INTERNACIONAL | HONG KONG | ELUSION FISCAL
In:
Derivatives & Financial Instruments v. 20, n. 4, July/August 2018, 5 p. Summary: To implement the minimum standards of the BEPS package promulgated by the OECD, the fundamental transfer pricing rules have been recently introduced in Hong Kong. These rules enshrine the arm's length principle for transactions between associated persons and the attribution of profits to a non-resident person's permanent establishment in Hong Kong in accordance with the authorized OECD approach (AOA). However, the application of AOA and other recommendations of the BEPS Project may result in different tax implications when compared with the long-standing territorial source principle of taxation in Hong Kong, which is explored in this article.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | DFI/2018/4-2 (Browse shelf) | Available | DFI/2018/4-2 |
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Resumen.
To implement the minimum standards of the BEPS package promulgated by the OECD, the fundamental transfer pricing rules have been recently introduced in Hong Kong. These rules enshrine the arm's length principle for transactions between associated persons and the attribution of profits to a non-resident person's permanent establishment in Hong Kong in accordance with the authorized OECD approach (AOA). However, the application of AOA and other recommendations of the BEPS Project may result in different tax implications when compared with the long-standing territorial source principle of taxation in Hong Kong, which is explored in this article.
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