International tax: Transfer pricing (principles, cases, and planning) - Workshop 2026

Multinational groups now operate in a world where transfer pricing is driven by OECDled international standards, rapidly evolving case law and increasingly assertive tax authorities. This seminar examines core transfer pricing principles from a global perspective and explains how Hong Kong has adopted and applied those principles through the Inland Revenue (Amendment) (No. 6) Ordinance 2018, key DIPNs and recent IRD practice.

Drawing on recent international transfer pricing cases and Hong Kong advance rulings and Board of Review decisions, the speakers will illustrate how global trends translate into practical Hong Kong tax consequences, including documentation expectations, dispute risk and planning opportunities.

This session explores how modern transfer pricing rules operate globally and what they mean for Hong Kong taxpayers. It links OECD transfer pricing principles and BEPS developments with Hong Kongs statutory regime, key practice notes and IRD expectations.

Using recent international cases, Hong Kong rulings and Board of Review decisions, it highlights planning options, documentation musthaves and common risk areas in areas such as intangibles, intragroup services and financing. Participants will gain practical tools to design defensible policies, manage doubletaxation risk and handle reviews, audits and APAs from a Hong Kong perspective.

Key topics covered:

International TP principles and OECD perspective
Hong Kong implementation rules and guidance
Recent international and Hong Kong cases
Planning, documentation and dispute prevention

Trainer:

Dr Percy Wong is the Programme Leader of the BBA Hons in Accountancy at The Hong Kong Polytechnic University (PolyU), where he teaches accounting and taxation at both undergraduate and postgraduate levels. He has over 30 years of experience in tax consultancy and education. Dr Wong is a joint editor of the Asia Pacific Journal of Taxation and coauthor of Hong Kong Taxation A Practical Guide, a widely adopted reference for professional examinations. He serves on the Council of the Taxation Institute of Hong Kong and was a former member of the Hong Kong Inland Revenue Board of Review.