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The TP Ordinance does not change the long-standing territorial source principle of taxation of the Hong Kong, under which taxpayers are subject to profits tax only if they have Hong Kong sourced revenue profit derived from a trade, business, or profession carried on in Hong Kong.

Furthermore, it is not clear whether the DEMPE considerations will change the way in which the IRD would evaluate offshore claims for royalties by taxpayers. Although transfer pricing adjustments will be imposed by the IRD under the new Section 50AAK to counter potential Hong Kong tax advantage obtained, it should be noted that the contemporaneous transfer pricing documentation requirement, while encompassing the business scale exemption and transaction amount threshold exemption, does not provide an exemption for offshore sourced transactions undertaken by a taxpayer.

Hence it remains unclear as to whether and how the IRD may prolong the review of the offshore claim or even reject an offshore claim, in this respect.


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In any case, Hong Kong taxpayers should ensure that the functional analysis included in the transfer pricing documentation should be consistent with the factual basis of the offshore claim. In essence, taxpayers when conducting the contribution analysis for the value chain should also take into account the specific locations of such activities to ensure that they support each other in the offshore claim. The tricky point is that the source of the interest income for a Hong Kong taxpayer carrying on intra-group financing business would be determined by operation test i.

Having regard to the assessment of preferential tax regimes as part of harmful tax practices under BEPS, the IRD has also introduced certain substance requirements as pre-conditions for taxpayers claiming the preferential tax rate i.

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In principle, such substance requirements include respective threshold on the number of full time employees in Hong Kong with the appropriate qualifications, and the amount of operating expenditure incurred in Hong Kong. Nevertheless, the TP Ordinance does not specify the precise threshold levels, and these will be determined and gazetted by the IRD at a later stage.

Students were instructed to inject the animals with various drugs and monitor their responses or to practice surgical procedures. After the training, of course, the animals were killed.

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Barnard said that he worked to stop these animal labs for medical students for two reasons: First, because of the obvious cruelty to animals, and second, because when medical students are trained to kill these animals, they come to believe that killing animals is somehow essential to medicine and science.

He of course disagreed.

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None of the 44 surveyed medical schools that have opened in the USA since have used animals to train students. In , the Physicians Committee persuaded the medical schools of Harvard and Columbia to eliminate their physiology dog laboratory course. In , the last medical school in Canada, the Memorial University of Newfoundland, ended the practice.

INSIGHT: Nine Interesting Facts About the New Hong Kong Transfer Pricing Regime

Facts and ideas from anywhere. Author: William C.

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