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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
| Test | Threshold |
|---|---|
| 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 |
Case-specific decisions differ — book a consultation with our advisers.
The content of this page is general professional information and does not constitute tax, legal or investment advice. For specific cases, please consult a Hong Kong practising accountant or tax adviser, or refer to official publications of the IRD / SFC / HKMA / CR.
