Tax Alert 02

New transfer pricing rules in Mongolia

The Ministry of Finance and the Mongolian Tax Administration (“MTA”) have developed regulations strengthening the current transfer pricing (“TP”) rules.
The new regulations define the covered transactions more specifically, introduce the tools for analysing TP, determine TP documentation, stipulate the reporting requirements and establish other important rules.
The major issues include:

TP Methodology
The previous Methodology for setting benchmark prices* (in force since 2007) was replaced by the new Methodology*, which now became publicly available. The new Methodology establishes detailed rules based on the OECD’s TP Guidelines for Multinational Enterprises and Tax Administrations.
The Methology includes the following
Scope of TP regulations (covered transactions)
- TP rules will apply to virtually all types of transactions between related parties.