Over the past two decades, transfer pricing has become one of the most important international tax issues. Transfer pricing is a neutral concept that simply refers to the determination of transfer prices for transactions between associated parties. But, a common way for MNCs to shift profits is through the manipulation of transfer prices. MNCs can charge artificially low or high prices for sales between related parties, thereby shifting profits and reducing their overall tax liabilities (de Mooij and Liu, 2020). It can therefore have a direct impact on a country’s tax base. To protect its tax base from being eroded through transfer mispricing, a country needs to have appropriate transfer pricing legislation and take steps to ensure that it is effectively administered.
Ⅰ. Introduction
Ⅱ. Mongolian investment environment
Ⅲ. BEPS and TPR in Mongolia
Ⅳ. Conclusion