The Departmental Interpretation and Practice Notes (DIPN) No. 48 Advance Pricing Arrangement (APA) issued in 2012 has been revised (revised DIPN 48) to provide more guidance for taxpayers on the procedures and requirements to pursue APAs. In this article, Cecilia Lee, Transfer Pricing Leader, Wengee Poon, Transfer Pricing Partner, and Tiffany Wu, Transfer Pricing Partner at PwC Hong Kong discuss key changes and aspects of the revised DIPN 48.
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