The Inland Revenue (Amendment) (No.6) Ordinance 2018 (the “Amendment Ordinance”) passed into law in July 2018, introduces statutory transfer pricing regime and implements various minimum standards under the Organisation for Economic Co-operation and Development (“OECD”)’s Base Erosion and Profit Shifting (“BEPS”) Action Plans. The Amendment Ordinance adopts the three-tier documentation structure, comprising a Master File, Local File and Country-by-Country Reporting (“CbCR”) recommended in the OECD BEPS Action Plan 131.