Transfer Pricing Services

Transfer pricing is another challenge for international businesses with operations in China and Hong Kong. The increased volume of cross-border transactions has made transfer pricing becoming a complicated issue. Transfer pricing audits in China can result in retroactive review of up to ten years.

With the Chinese and Hong Kong tax authorities tightening their grip on transfer pricing enforcement with additional resources and regular audits, businesses must act accordingly to prevent adverse predicaments that may potentially result in heavy fines and additional tax payments. Hong Kong tax authority had issued transfer pricing guidelines for strengthening the management on transactions between associated companies.

Over the past decade, our Crowe Transfer Pricing team in Hong Kong has assisted our multinational and Hong Kong clients in numerous Transfer Pricing exercises.

We have successfully persuaded tax authorities across Mainland China and Hong Kong to agree on the existing Transfer Pricing mechanism of our clients or reached consensus with the tax authorities to achieve tax savings.

We have in-depth Transfer Pricing experience in the following areas:

• Master Files and Local Files in Hong Kong.
• Transfer Pricing contemporaneous documentation in Mainland China.
• Transfer Pricing benchmarking analyses for supporting the reasonableness of transactions with overseas related entities.
• Answering enquiry letters from the Hong Kong Inland Revenue Department regarding the authenticity, commercial needs and charging basis of related party transactions.
• Transfer Pricing defense in both Mainland China and Hong Kong.
• Transfer Pricing planning to establish a proper pricing arrangements and documentation system during the pre-start-up phase of your business.
• Transfer Pricing risk assessment and advice on how to improve the existing Transfer Pricing arrangements and establish a defensible position.
• Health check on the current business and transactional models from the Transfer Pricing perspective.

Our sophisticated Transfer Pricing team members provide high level technical services and innovative solutions to solve complicated and challenging Transfer Pricing and tax matters.

We will be pleased to share our experience and ideas with you to achieve your business objective. If you are interested in our Transfer Pricing and tax services, please feel free to contact our Tax Partner Cyrus Chow by email to [email protected] or by phone at +852 2894 6835 for enquiry.