On 15 July 2020, the Inland Revenue Department (IRD) of Hong Kong released the DIPON 48 regarding advance pricing arrangement (APA) procedures. The Departmental Interpretation and Practice Notes No. 48 has been updated mainly to (a) reflect the legislative changes made by the Inland Revenue (Amendment) (No. 6) Ordinance 2018 in relation to the statutory advance pricing arrangement (APA) regime and (b) explain the streamlined APA process.
The publication contains information on definitions and types of APA; the three-staged application procedure of an APA; application of transfer pricing guidelines for multinational enterprises; rollback and withdrawal of an APA; and 4) applicable penalties and additional taxes due to non-compliance of obligations. The notes replace those issued in March 2012.
