Getting Their Fair Share: Capacity building on transfer pricing pays dividends for Mongolia

Mongolia utilized technical assistance from the Intergovernmental Forum on Mining (IGF), the OECD, and Tax Inspectors Without Borders (TIWB) to address tax base erosion and profit shifting (BEPS) in its mining sector. By establishing a transfer pricing division in 2019 and implementing new regulations on license valuation and ring-fencing, the Mongolian Tax Authority successfully recovered USD 228 million from a single multinational audit and USD 8.7 million from license transfers.

• Mongolia established its first transfer pricing division by October 2019 to address the manipulation of internal transaction prices by multinational mining companies, which had previously exploited the government's limited human resources to avoid taxes.
• A comprehensive audit of a large multinational mining company, supported by international technical assistance, resulted in the collection of USD 228 million in tax revenue by the end of 2020 and the denial of USD 1.5 billion in carried-forward losses.
• The introduction of Decree 302 in 2019, which established new regulations for the valuation of mining and exploration licences for capital gains tax, prevented companies from selecting the lowest-tax valuation method and generated approximately USD 8.7 million in taxes across 246 licences.
• In 2020, Mongolia implemented ring-fencing rules to stop mining companies from consolidating income and costs across different projects to delay corporate income tax payments.

APA

International Institute for Sustainable Development (2022). Getting Their Fair Share: Capacity building on transfer pricing pays dividends for Mongolia. https://www.iisd.org/articles/success-story/capacity-building-transfer-pricing-mongolia

Chicago

International Institute for Sustainable Development. Getting Their Fair Share: Capacity building on transfer pricing pays dividends for Mongolia. 2022. https://www.iisd.org/articles/success-story/capacity-building-transfer-pricing-mongolia.

Wikipedia

{{cite report |author=International Institute for Sustainable Development |title=Getting Their Fair Share: Capacity building on transfer pricing pays dividends for Mongolia |date=11 August 2022 |url=https://www.iisd.org/articles/success-story/capacity-building-transfer-pricing-mongolia |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{internationalinstituteforsustainabledevelopment2022getting, author = {{International Institute for Sustainable Development}}, title = {{Getting Their Fair Share: Capacity building on transfer pricing pays dividends for Mongolia}}, institution = {International Institute for Sustainable Development}, year = {2022}, month = aug, url = {https://www.iisd.org/articles/success-story/capacity-building-transfer-pricing-mongolia}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }