Mongolia: First transfer pricing tax assessment

Mongolia: First transfer pricing tax assessment

The Organisation for Economic Cooperation and Development (OECD) today announced that the Mongolian tax administration issued its first transfer pricing assessment, in the amount of U.S. $228 million.


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According to the OECD release:

  • Since 2019, the OECD and others have worked with the Mongolian tax administration to strengthen revenue collection from the extractives sector.
  • As a result of mining tax audit capacity-building initiatives, the Mongolian tax administration issued its first transfer pricing tax assessment in late 2020 for approximately U.S. $228 million and denied U.S. $1.5 billion in loss carryforwards.
  • The assessment was reported by the taxpayer’s parent corporate entity on 23 December 2020. The matter is currently being disputed.  

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