Transfer Pricing Regulation in Mongolia

The transfer pricing mechanism is a tool commonly used to transfer the tax base from countries with high taxation in countries with low taxation. In many countries, this financial operations generate significant tax revenue losses. In an attempt to limit tax revenue losses, many public authorities have introduced regulations on transfer pricing, but the effectiveness of these rules has proved limited, and they contributed to the increasing complexity of tax laws and to the appearance of additional costs for companies. Historically, transfer pricing (TP) was not a substantial issue in Mongolia. The tax legislation contains basic TP rules, but there is limited guidance and enforcement in practice. At the moment, Mongolian tax authorities are not conducting specific transfer pricing audits. Nevertheless, tax authorities are starting to pay more attention to transactions between related parties and potential transfer pricing adjustments. This study examines a transfer pricing regulations of Mongolia.