Mongolia has introduced a transfer pricing documentation framework in line with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative.
The framework is designed to enhance transparency in transactions between multinational group companies. Taxpayers are required to document and demonstrate that transactions between related parties have been conducted in accordance with the arm’s length principle.
Four Types of Transfer Pricing Reports
- Annual Transfer Pricing Transaction Report
- Local File
- Master File
- Country-by-Country Report (CbC Report)
Obligations of Foreign-Invested Companies and Permanent Establishments
Foreign-invested companies and permanent establishments operating in Mongolia are required to prepare and submit the following three reports to the Mongolian Tax Administration:
✅ Annual Transfer Pricing Transaction Report
✅ Local File
✅ Master File
Our Services
- Transfer pricing risk assessment
- Professional support in preparing the Local File and Master File
- Review of related-party transactions and supporting documentation
💡 For foreign-invested companies operating in Mongolia, early preparation is essential to ensure compliance and proactively manage potential tax risks.
