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Documentation thresholds

Documentation thresholds

A Master File and Local File may be dispensed with only if the size test (two of three) and the related-party transaction test are both met (see table). A Local File must be in place within 9 months of the accounting period end, and submitted within one month of an IRD request. Companies near the thresholds should plan on preparing the files rather than assuming small size is a safe harbour.

Master File / Local File exemption thresholds

TestThreshold
Size test (two of three)Revenue ≤ HK$400m / assets ≤ HK$300m / staff ≤ 100
Related-party transfers of goods≤ HK$220m
Related-party transfers of intangibles≤ HK$110m
Other related-party transactions (services, interest, etc.)≤ HK$11m

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