Hong Kong to implement parent-surrogate country-by-country tax reporting for multinationals

Hong Kong’s Inland Revenue Department on December 22 issued more guidance on country-by-country reporting for large multinationals, including announcing that the tax agency intends to accommodate parent-surrogate filing for Hong-Kong parented groups.

Under this transitional arrangement, a Hong Kong multinational group will be allowed to file a country-by-country report for accounting periods beginning between January 1, 2016, and December 31, 2017, with the Hong Kong tax agency, which will in turn exchange the report with other tax jurisdictions.

The notice states that the required legal framework for such transition relief has not yet been put in place in Hong Kong and qualified competent authority agreements still must also be signed for parent-surrogate filing to be effective. It also sets out the notifications that must be submitted to the tax agency by the Hong Kong parent.


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