The Inland Revenue (Amendment) (No. 6) Ordinance 2018 was gazetted on 13 July 2018 which implements the minimum standards of the Base Erosion and Profit Shifting (BEPS) package promulgated by the Organisation for Economic Co-operation and Development (OECD) and codifies the transfer pricing principles into the Inland Revenue Ordinance (Cap. 112).

Under the Amendment Ordinance :

• A Hong Kong ultimate parent entity of a multinational enterprise group is required to file country-by-country [“CbC”] reports if the annual consolidated group revenue exceeds HK$6.8 billion.
  
  
• A Hong Kong taxpayer is required to prepare master file and local file as part of the transfer pricing documentation, subject to certain exemptions.
  
  
• A CbC report has to be prepared for accounting periods beginning on or after 1 January 2018.  Master file and local file are required for accounting periods beginning on or after 1 April 2018. 
  
  
• Taxation of income derived from intellectual property by non-resident associates and Attribution of income or loss to non-resident persons' permanent establishments in Hong Kong will apply for years of assessment beginning on or after 1 April 2019.

For details, please refer to the below full text of the Inland Revenue (Amendment) (No. 6) Ordinance 2018.

Inland Revenue (Amendment) (No. 6) Ordinance 2018