The Inland Revenue (Amendment) (No. 6) Ordinance 2018 (the BEPS and TP Ordinance) was gazetted to codify TP rules in Hong Kong. With the formal introduction of the TP regulatory regime into Hong Kong tax legislation, the Inland Revenue Department (“IRD”) is following the global trend and taking a more aggressive approach on reviewing TP issues in cross-border intercompany transactions. TP-related tax disputes became one of the major tax controversy areas and the difficulties in resolving TP-related disputes with the IRD has been heighten. On the positive side, using TP methodology to resolve prolonged and comprehensive tax disputes cases become more receptive and acceptable by the IRD.
In view of this, we will share with you the below insights:
• Recap of the introduction of the TP legislation in Hong Kong
• Latest development of TP-related tax controversy issues
• How to resolve TP-related tax disputes
• How to use TP methodology to resolve tax audits
• Precaution measures to prevent potential TP-related tax disputes
• Real life case studies
Ms. Karen AU, Partner, Tax Controversy Services, PwC
Karen is a Partner at PwC Hong Kong. She has over 15 years of experience in assisting clients in resolving Tax Controversy cases with the Hong Kong Inland Revenue Department and focusing on tax audit and investigation.
Karen has been providing HK tax controversy and business advisory to local, regional and multinational clients, particularly those in the industries of apparel and electronic manufacturing, pharmaceutical, general trading, sourcing, financial services and asset management.
Mr. Brian WONG, Manager,Transfer Pricing Services, PwC
Joined PwC in 2013, Brian has extensive experience in providing professional advices to multinational enterprises on transfer pricing matters from both China and Hong Kong perspectives, and in coordinating global and regional projects involving different tax jurisdictions.
His experience includes assisting clients in revisiting their transfer pricing structures, formulating transfer pricing models, preparing transfer pricing documentation, handling transfer pricing-related investigations by tax authorities, performing risk assessments and providing implementation advices.
Ms. Joyce CHAK, Manager, Tax Controversy Services, PwC
Joyce is a Tax manager at PwC Hong Kong. Prior to joining PwC Hong Kong, she had been working in the Hong Kong Inland Revenue Department (“IRD”) for more than 6 years under the Profits Tax Unit and the Field Audit and Investigation Unit.
Joyce has been providing HK tax controversy and business consulting services, including handling tax audit and investigation cases and prolonged profits tax disputes with the IRD for listed companies, multinational enterprises and local clients. Joyce has successfully assisted clients in resolving various tax issues, including offshore claim and settling tax disputes with the IRD.
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