Transfer Pricing Services

At CityLinkers, we help businesses proactively manage their transfer pricing exposure through thorough risk assessment and strategic guidance. Our team conducts detailed reviews of both cross-border and domestic related-party transactions to identify potential tax risks and assess alignment with Hong Kong’s transfer pricing regulations and OECD guidelines.

We provide customised risk reports that offer in-depth analysis and actionable recommendations, enabling clients to enhance pricing consistency and reduce the likelihood of audit challenges. Additionally, we assist in forecasting audit risks by identifying common areas of focus for the Hong Kong Inland Revenue Department (IRD), allowing businesses to prepare robust, defensible documentation before issues arise.

Through early identification and strategic planning, our transfer pricing risk assessment services help you maintain compliance, improve transparency, and safeguard your tax position.

CityLinkers provides tailored transfer pricing policy development services that ensure your intra-group transactions are both commercially viable and fully compliant with regulatory requirements. We design pricing models that adhere to the arm’s length principle using accepted methods such as Comparable Uncontrolled Price (CUP), Cost Plus, Resale Price, Transactional Net Margin Method (TNMM), and Profit Split—selecting the most appropriate approach based on the nature of your transactions and industry practices.

Our policies are carefully aligned with both the Hong Kong Inland Revenue Ordinance and the OECD Transfer Pricing Guidelines, ensuring consistency with local and international standards. In addition, we advise on group-wide tax structuring to optimise intra-group pricing strategies and support tax efficiency across multiple jurisdictions. By integrating policy design with broader tax planning objectives, we help clients establish sustainable, defensible transfer pricing frameworks that withstand regulatory scrutiny and adapt to evolving business needs.

Maintaining comprehensive and compliant transfer pricing documentation is critical under Hong Kong’s transfer pricing regime and global tax standards. At CityLinkers, we assist clients in preparing all required documentation, including the Master File and Local File, tailored to reflect the nature, scale, and complexity of their business operations. Our documentation is aligned with both the Hong Kong Inland Revenue Department’s requirements and OECD guidelines, ensuring clarity, consistency, and defensibility.

For multinational enterprises subject to Country-by-Country Reporting (CbCR), we provide end-to-end support in compiling accurate data and submitting timely reports in accordance with statutory thresholds. In addition, we help businesses implement robust internal document management systems to support the annual maintenance and timely updating of transfer pricing records, reducing the risk of compliance lapses and audit challenges.

By ensuring documentation is complete, current, and strategically prepared, CityLinkers empowers clients to meet regulatory expectations and respond confidently to tax authority inquiries.

When transfer pricing matters come under scrutiny, CityLinkers provides strategic support to help businesses navigate inquiries, defend their positions, and resolve disputes effectively. We represent clients in all interactions with the Hong Kong Inland Revenue Department (IRD), including audits, information requests, and proposed pricing adjustments, ensuring that responses are accurate, well-documented, and aligned with applicable regulations.

To reduce uncertainty and prevent future disputes, we assist with the preparation and negotiation of Advance Pricing Agreements (APAs), offering clients the opportunity to secure tax certainty on related-party transactions for future years. Additionally, for cases involving cross-border double taxation, we support clients in initiating and managing Mutual Agreement Procedures (MAPs) with foreign tax authorities, facilitating the resolution of disputes through cooperative dialogue between jurisdictions.

With deep technical expertise and strong regulatory insight, CityLinkers helps clients manage transfer pricing controversies with confidence, professionalism, and a focus on practical, lasting solutions.

CityLinkers provides comprehensive support to help businesses strengthen their internal capabilities and maintain ongoing compliance with transfer pricing and related regulatory requirements. We advise clients on their obligations under Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) protocols, and disclosure frameworks to ensure full alignment with both local laws and international standards.

To build internal expertise, we deliver customised training workshops for tax, finance, and accounting teams, equipping them with the knowledge needed to manage transfer pricing documentation and respond effectively to regulatory inquiries. These sessions are tailored to your industry and operations, ensuring relevance and practical value.

Additionally, we assist in developing and implementing internal control mechanisms to monitor compliance on a continual basis. This includes setting up systems to track related-party transactions, maintain accurate records, and manage documentation updates—helping reduce risk and enhance operational readiness.

CityLinkers combines a deep understanding of international transfer pricing standards with in-depth knowledge of regional tax regulations in Hong Kong, Mainland China, and beyond. This dual perspective allows us to bridge global requirements with local expectations, providing clients with practical, commercially relevant advice that meets both OECD guidelines and jurisdiction-specific compliance needs. Our globally aligned yet locally grounded approach ensures that your transfer pricing strategies are both effective and defensible.

At CityLinkers, we take a proactive, risk-first approach to transfer pricing compliance. By conducting thorough reviews of your existing policies, documentation, and transaction structures, we help identify potential vulnerabilities before they attract regulatory scrutiny. This forward-looking strategy ensures your business remains audit-ready and dispute-resistant, significantly reducing the risk of penalties and transfer pricing adjustments. Our focus on early detection and prevention allows clients to operate with greater confidence in an increasingly regulated environment.

At CityLinkers, we prioritise efficiency and transparency throughout every stage of your transfer pricing engagement. From initial consultation to final deliverables, we provide clear communication, defined project timelines, and regular progress updates to ensure you are fully informed and in control. Our structured approach minimises disruption to your operations while delivering timely, accurate results—fostering trust, clarity, and a seamless client experience.

Transfer pricing, when approached strategically, offers far more than compliance—it can drive operational efficiency, reduce tax exposure, and support long-term business growth. By partnering with CityLinkers as your trusted transfer pricing advisor, you gain access to tailored solutions that transform regulatory obligations into a source of competitive advantage.

Our experienced team helps you mitigate audit risk, optimise tax efficiency, and maintain consistency across global operations. Whether you're developing a new transfer pricing policy, preparing documentation, or navigating complex cross-border disputes, we are here to support your success in an increasingly demanding international tax landscape.

To explore how our transfer pricing services can enhance your global tax strategy, please contact us. We look forward to assisting you.