Source, Transfer Pricing, and Anti-Avoidance: Further Developments
Bulletin for International Taxation, Vol. 64, p. 350, June 2010
3 Pages Posted: 2 Jun 2010
Date Written: March 15, 2010
Abstract
This short article discusses several recent developments in Hong Kong taxation since the publication, in the December 2009 issue of the Bulletin for International Taxation, of the article entitled “Source, Transfer Pricing and Anti-Avoidance: The Position After Ngai Lik and Datatronic.” The developments relate to the source of profits for tax purposes, the issuance of administrative guidance on transfer pricing (despite the lack of a statutory transfer pricing provision), and new case law on the application of Hong Kong's general anti-avoidance rule.
Keywords: Hong Kong taxation, source of profits, transfer pricing, general anti-avoidance
JEL Classification: K34
Suggested Citation: Suggested Citation