Intra-group financing activities in Hong Kong and Hong Kong treasury centres
Intra-group financing activities
Hong Kong Tax Alert - Issue 12, September 2016
Intra-group financing arrangements now form a key part in the transfer pricing master file under the OECD Base Erosion and Profit Shifting initiatives, together with the increase in information transparency these arrangements now need to be properly supported and documented. In addition, Hong Kong is promoting itself as a potential regional treasury hub and has introduced tax incentives. This tax alert provides a brief overview of the newly introduced Corporate Treasury Centre incentives and highlights typical treasury related transactions or areas which companies should consider with respect to transfer pricing.