Hong Kong SAR


Practice area

World TP Reviews

Transfer pricing
Baker McKenzie

Baker McKenzie has extensive experience and a well-established transfer pricing practice in Hong Kong. The firm assists clients with audit defence, establishing innovative planning structures, documentation and implementing bilateral APAs. The team has a network of offices and works with lawyers who provide clients with technical analysis. It also holds regular transfer pricing seminars for clients, highlighting recent transfer pricing developments.


Eunice Kuo is the head of the transfer pricing practice at Deloitte. The transfer pricing team assist clients with handling documentation to support clients’ transfer pricing operations and dealing with disputes. It aligns practical transfer solutions with its global business operation to help clients manage risk. It provides services including APAs, business model optimisation and the facilitation of transfer pricing risk management. It has maintained a close relationship with the local tax authorities by providing practical operation training to officials at different levels, involving state, provincial and municipal administration of tax.

DLA Piper

The transfer pricing team at DLA Piper is comprised of lawyers, economists and certified tax advisers. It assists clients with developing and implementing a practical global transfer pricing policy, and supporting and defending the policy in various jurisdictions. 

Daniel Chan, Anderson Lam, Peng Tao and Patrice Marceau advised a manufacturing and distribution group on tax and transfer pricing matters in 2017. DLA Piper offered the client a comprehensive US, Hong Kong and China tax and transfer pricing services in restructuring its APAC sourcing operations. In this case, the team provided a seamless integrated approach to get an overall restructuring that is BEPS-compliant yet retaining certain US tax benefits.


The transfer pricing team is comprised of four partners and 45 practitioners at EY. The practice assists Hong Kong outbound firms in BEPS compliance. The transfer pricing team has a dispute resolution ability, which can help clients to conclude bilateral APA, MAP and domestic transfer pricing deals. The transfer pricing team also provides technology–based solution that assist Hong Kong groups and multinational companies’ regional headquarters to deal with compliance and risk management needs with cost efficiency.

In 2017, Martin Richter, Kenny Wei and Justin Kyte advised Hong Kong outbound companies on BEPS-related services. It also provided a one-stop solution to address the new challenges in the transfer pricing practice. The transfer pricing team offered insightful opinions on BEPS Action 13 and used a technology-based solution. It helped client improve its transfer pricing structure and compliance.


Karmen Yeung is the head of the transfer pricing practice at KPMG. Yeung provides inbound investment structure advice to clients, including corporate holding, structure, financing, the form of investment and fund repatriation strategies. The transfer pricing team helps clients in complying with the BEPS initiatives by conducting BEPS transfer pricing planning, review and documentation projects from a regional and global view. The team has developed technology tools, such as Tax Intelligence Solution (TIS), to advise clients in dealing with transfer pricing compliance.

Chen Lu helped one of the largest international shipping groups in a matter concerning a global BEPS-TP risk assessment and documentation project. The transfer pricing team assisted the client with global BEPS-TP risk assessment and preparation of Country-by-Country Reporting. It also offered a review of the global BEPS-TP defence mechanism of the group, preparing master files and local files globally.