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Transfer of intangibles: HKD 110 million; and Any other transaction (e.g. service income and royalty income): HKD 44 million. Note: If the enterprise is fully exempted from preparing a local file by reason of its related party transactions of all categories are below the prescribed thresholds, it will not be required to prepare the master file either.

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 · Introduction. Transfer pricing is a term used to define the price charged between associated enterprises for the transfer of goods, services and intangible property. Increasing cross-border activities have made transfer pricing a real issue as enterprises seek to use transfer pricing as a tool for tax avoidance.

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