Title: Enactment of Macao's new tax code: Transfer pricing and other new tax rules  

Presenters: Ka Yan Pau, and Flora Zeng
Date: 8 April 2025, Tue, 3:00 PM SGT (GMT +8)

On 16 December 2024, the legislative assembly of Macao passed the bill for approval of the Tax Code (hereinafter referred to as the "Bill") after detailed discussions and voting. The Bill was officially promulgated as Law No. 24/2024 on 30 December 2024. Structurally, the Bill is divided into two parts:

I. The Approval Law of the Tax Code (twenty-nine articles); and
II. The main body of the Tax Code (three hundred and twelve articles)

The Approval Law of the Tax Code (Part I) primarily focuses on revising and adapting the existing tax regulations in Macao, which includes modifications and updates to specific articles of the legislation such as the Industrial Tax Regulation, Professional Tax Regulation, and Complementary Tax Regulation. These revisions aim to align with the new regulations outlined in the main body of the Tax Code while incorporating mechanisms that align with international tax standards.  For example, this part introduces important concepts such as transfer pricing and elimination of double taxation in the Complementary Tax Regulation.

The main body of the Tax Code (Part II) establishes a unified foundation of tax concepts, taxing principles, and regulations that govern the tax legislative framework and integrated with the legal framework of Macao. It introduces several key new taxation concepts, including definitions of tax resident, permanent establishment, territorial applicability (territorial principle), tax domicile, and tax agent, thereby consolidating and clarifying the foundational structure of Macao tax system.  According to Article 29 of the Approval Law of the Tax Code (Part I), the law and its approved Tax Code will officially come into effect on January 1, 2026.

We invite you to join our upcoming Dbriefs webcast, where Deloitte tax experts will highlight and interpret the key points of the Macao Tax Code that have garnered attention from the industry. Drawing insights from recent seminars organized by the Macao Financial Services Bureau, we will provide an analysis on the new regulations and their implications. Don’t miss out!