Can you exlain the below slide? It is talking about Hong Kong Tax, Special business, Financial Instituition, calculating the profit tax. Transfer pricing▸ Implementation to TP Rule:• 3-tiered structure of TP documentationоCountry-by-country reportingInformation relating to the global allocation of income and taxes paidMaster file•Information relevant for all constituent entities of the groupLocal file• Information related to material transactions of a specific constituententityPenalty.S.82A(1C) and (1D): penalty of 100% of the difference betweenamount filed by taxpayer and the adjusted amount by the IRDHowever, NO penalty if reasonable efforts are made to determinethe transfer pricing (i.e. with proper TP documentations)79

The question is asking for an explanation of the transfer pricing rules in Hong Kong, the…

Answered: Transfer pricing ▸ Implementation to TP…

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