On 29 December 2017, Inland Revenue (Amendment) (No. 6) Bill 2017 published in order to sets out rules on transfer pricing documentation including country-by-country reporting, and contains other measures to implement the minimum standards under BEPS.

 Under the Bill, Hong Kong constituent entities of a group will be required to prepare a master file for each accounting period beginning on or after 1 April 2018. Exemption thresholds for master file remain the same as previously proposed in the Consultation Report.