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Transfer pricing ▸ Implementation to TP Rule: • 3-tiered structure of TP documentation о Country-by-country reporting Information relating to the global allocation of income and taxes paid Master file • Information relevant for all constituent entities of the group Local file • Information related to material transactions of a specific constituent entity Penalty . S.82A(1C) and (1D): penalty of 100% of the difference between amount filed by taxpayer and the adjusted amount by the IRD However, NO penalty if reasonable efforts are made to determine the transfer pricing (i.e. with proper TP documentations) 79

Transfer pricing ▸ Implementation to TP Rule: • 3-tiered structure of TP documentation о Country-by-country reporting Information relating to the global allocation of income and taxes paid Master file • Information relevant for all constituent entities of the group Local file • Information related to material transactions of a specific constituent entity Penalty . S.82A(1C) and (1D): penalty of 100% of the difference between amount filed by taxpayer and the adjusted amount by the IRD However, NO penalty if reasonable efforts are made to determine the transfer pricing (i.e. with proper TP documentations) 79

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Can you exlain the below slide? It is talking about Hong Kong Tax, Special business, Financial Instituition, calculating the profit tax. 

Transfer pricing ▸ Implementation to TP Rule: • 3-tiered structure of TP documentation о Country-by-country reporting Information relating to the global allocation of income and taxes paid Master file • Information relevant for all constituent entities of the group Local file • Information related to material transactions of a specific constituent entity Penalty . S.82A(1C) and (1D): penalty of 100% of the difference between amount filed by taxpayer and the adjusted amount by the IRD However, NO penalty if reasonable efforts are made to determine the transfer pricing (i.e. with proper TP documentations) 79
Transcribed Image Text:Transfer pricing ▸ Implementation to TP Rule: • 3-tiered structure of TP documentation о Country-by-country reporting Information relating to the global allocation of income and taxes paid Master file • Information relevant for all constituent entities of the group Local file • Information related to material transactions of a specific constituent entity Penalty . S.82A(1C) and (1D): penalty of 100% of the difference between amount filed by taxpayer and the adjusted amount by the IRD However, NO penalty if reasonable efforts are made to determine the transfer pricing (i.e. with proper TP documentations) 79
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