Tax Services in Hong Kong


Transfer Pricing Services

Transfer pricing is the term used to describe all intra-group pricing arrangement between related business entities, and regularly applies to intra-group transfers of property and intellectual property (IP). This difficult topic makes it necessary for todays business owners to obtain transfer pricing services from experts. In times of globalised businesses and constant cross-border transactions, businesses need to keep an eye on their transfer pricing strategies and transfer pricing solutions as well as on the ongoing international developments, like the OECD’s Base Erosion and Profit Shifting Plan (BEPS). International intra-group transactions cross-borders are rapidly growing in number and complexity. Global integration and the business practices of our time challenge international businesses to be careful look out for the best transfer pricing services.

The transfer pricing services specialists of Mühler McKay in Hong Kong are experienced advisors and have designed transfer pricing services and strategies to assist your business in achieving your global objectives. The goal should always be to improve your businesses after tax profits and its cash flow in the growing global markets. Generally businesses can lower their necessary costs and minimise their risks by restructuring business operations, supply chains and cash flow streams. Mühler McKay can assist your business in developing appropriate tax and legal structures to optimise your entire business operation. We always keep in mind, that tax authorities around the world are imposing stricter penalties, require more sophisticated documentation and are generally more keen to tax business operations. This worldwide development makes transfer pricing services even more important.

Hong Kong does not have comprehensive transfer pricing legislation. But as Hong Kong joined the OECD’s BEPS Inclusive Framework Hong Kong committed to the consistent implementation of the BEPS package. The OECD’s top priority is to monitor the implementation of the four minimum standards, i.e. countering harmful tax practices, preventing treaty abuse, imposing country-by-country (CbC) reporting requirement and improving the cross-border dispute resolution regime. As of the consultation paper, Hong Kong will focus on the four minimum standards as well as measures of direct relevance to their implementation. The priority is to put in place the necessary legislative framework for transfer pricing rules which cover the latest guidance from the OECD, spontaneous exchange of information on tax rulings, CbC reporting requirement, the cross-border dispute resolution mechanism and the Multilateral Instrument. The OECD requires Hong Kong to have finished with the implementation in mid-2017. Mühler McKay will monitor the developments and will update its transfer pricing services offerings accordingly.

Our transfer pricing services generally include:

  • Assessing your businesses transfer pricing situation

Part of our transfer pricing services is to assess your transfer pricing situation in detail. Afterwards we will work out a strategy for a tax efficient structure which will give your business a better position among your competitors.

  • Hong Kong transfer pricing services

Hong Kong will get sophisticated BEPS rules. Therefore we are monitor the developments and will update our transfer pricing services for Hong Kong.

  • Tax efficient restructuring of your business operation, supply chain and cash flow streams

Our transfer pricing services also include assistance to you with structuring your entire business, your supply chain and your cash flow streams in a tax efficient manner especially in regard to transfer pricing issues. By this your overall tax liability is minimised at group level.

  • Dealing with different jurisdictions and their unique tax regulations

Because of our experience in rendering transfer pricing services to various clients, we are experienced in dealing with different jurisdictions and their unique tax regulations and can provide the necessary transfer pricing documentation for your business.

  • Supporting services

Mühler McKay also provides supporting services for business operations such as assistance with incorporation services / company formation services, advising on tax efficient legal structures for (groups of) companies (corporations, for instance a Hong Kong Limited Company, partnerships, branches, representative offices), bookkeeping and accounting (according to Hong Kong principles) as well as audit arrangement, general corporate compliance like provision of company secretary services (in Hong Kong) as well as providing a registered address or virtual office in Hong Kong, obtaining obligatory registrations, permits and licenses, as well as employment advice, including Hong Kong work visa application and general transfer pricing services.

Mühler McKay offers comprehensive transfer pricing services in Hong Kong and worldwide which include arranging businesses and operations in a tax efficient manner in order to bring down your effective global tax rate, satisfy international tax compliance obligations and mitigate taxation risks.

Please contact us or visit us in Hong Kong for your first consultation for our transfer pricing services.

Mühler McKay based in Hong Kong is a business advisory firm with worldwide reach and renders, among others, general international tax and expert transfer pricing services to a diversified international client base from various industries and sizes.