Transfer Pricing Services

Transactions within multinational companies are becoming increasingly important in business worldwide. For tax purposes, prices agreed between related parties have to meet the definition of arm’s length principle.

It’s been over many years now since Mongolia implemented price control regulations for tax purposes (“transfer pricing rules” or “TP rules”). Over this time, these rules remain vague and not properly detailed. However, recently a new understanding has developed with the state authorities of how important these rules are. The Mongolian Ministry of Finance and Mongolian Tax Authority have developed a number of draft regulations strengthening the current TP rules. Clearly, the tax authorities are now starting to focus on TP. Businesses with related-party transactions will need to extremely conscious of the TP requirements.

We have assembled an extremely strong TP team with team members have extensive Mongolian and foreign experience. Where need, PwC Mongolia is by technical experts from other countries. Our TP practice consists of more than 2500 specialists in 80 countries.

How PwC can help you

Advice on various TP matters

  • Whether the Mongolian TP rules apply to transactions of the company concerned?
  • What are the TP requirements you need to comply with?
  • How to structure your international operations from a TP perspective?
  • How to identify TP risks and mitigate them; how to design an internal function for dealing with TP?
  • How to prepare for an audit? In case of an ongoing audit or TP dispute, what are the options to defend your position and to establish a dialogue with the tax authorities?

TP compliance

  • Running a diagnostic on the Group’s existing controlled transactions from the perspective of the TP legislation
  • Assisting in preparation of the TP documentation/’defence’ file to substantiate the arm’s length level of prices applied
  • Performing benchmarking studies to determine the arm’s length profitability

Planning and TP policy development

  • Developing a unified methodology for determining prices in controlled transactions
  • Providing recommendations on improvements to pricing policies, in particular, by value chain transformation
  • Developing assisting in the creation of trading and procurement structures

Contact us

Michael Ahern
Tax Services Partner
Email

Tsendmaa Choijamts
Tax Executive Director
Tel: +976 70009089
Email

Maryna Tarnavska
Tax Manager
Tel: +976 70009089
Email

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