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Asia Transfer Pricing (10th edition)

  • Reaching the tipping point

    The OECD’s BEPS initiative has sparked a global focus on MNEs and their transfer pricing. In recent years, writes Tony Gorgas of KPMG Australia, there has been a profound change in the ASPAC region as governments and tax administrations seek to ensure multinationals pay their fair share of tax in line with economic and value creation.

  • US corporate tax reforms – impact on the Asia Pacific region

    Tony Gorgas, Jay Mankad, Jennifer Goldkopf, Cheng Chi, Yosuke Suzaki, Jee-Won Shin, Shamila Jayasekara, and Anita Lin of KPMG review the changes in US tax legislation and discuss their specific impact on jurisdictions around the Asia-Pacific region.

  • Asia Pacific – a harmonious interplay between transfer pricing and customs valuation?

    The rise of integrated supply chains, complex organisational structures and inter-company transactions, means the harmonious interplay between customs valuation and transfer pricing has never been more important, writes Leonie Ferretter of KPMG. However, across the Asia Pacific region, we continue to see disparity in how TP is treated from a customs perspective.

  • Transparency is trending

    Over the past year, the Australian transfer pricing (TP) landscape has continued to evolve. There is new legislation and the Australian Taxation Office (ATO) is continuing to prioritise TP as a key area, write Tim Keeling, Jay Mankad and Jennifer Goldkopf of KPMG.

  • TP in China: SAT tapping into the tax big data paradise

    As explained by Cheng Chi, Rafael Triginelli Miraglia and Choon Beng Teoh of KPMG, transfer pricing continues to be one of the Chinese State Administration of Taxation’s key areas of focus, as new policies and methodologies are being examined post-BEPS to strengthen the SAT’s monitoring of multinational enterprises’ TP

  • The transfer pricing landscape in India

    Almost two decades after the introduction of transfer pricing regulations in 2001, the Indian TP space has evolved and matured immensely, write Manoj Pardasani, Hasnain Shroff and Hardev Singh of BSR & Co. Today, India’s TP regulations are in line with international TP principles and the Indian government is continuing to align the TP regulations with global best practices.

  • Indonesia’s rapid transfer pricing evolution

    Indonesia completed the last step in the introduction of new transfer pricing regulations late last year, report Iwan Hoo, Aaron Brunier and Fachrur Rifqi Nugroho of KPMG. While the regulations covering the master file, local file and country-by-country reporting were issued in 2016, the implementing regulations for CbCR were not completed until late December 2017.

  • Update on Japanese transfer pricing 2018

    Recent changes in the business environment and the financial situation of the Japanese government have affected the Japanese taxation environment and transfer pricing regulations, explain Jun Tanaka, Nobuhiro Tsunoda and Yosuke Suzaki of KPMG in Japan.

  • Recent tax reform to align with the OECD BEPS Action Plan

    The National Assembly of Korea approved the 2017 Tax Reform Bill on December 5 2017, write Gil Won Kang, Sang Hoon Kim and Seung-Mok Baek of KPMG.

  • New government – transfer pricing as usual?

    The Pakatan Harapan coalition formed a new government in May 2018 after defeating the Barisan Nasional coalition that had ruled the country for more than six decades, write Bob Kee and Mei Seen Chang of KPMG. This major shift in the political landscape of Malaysia is affecting the economic and business environment.

  • NZ BEPS monster on the horizon

    The New Zealand transfer pricing landscape has changed rapidly over the past year, explain Kim Jarrett, Kyle Finnerty and Nadia Fediaeva of KPMG. With new BEPS legislation enacted, increased tax enforcement efforts, the Inland Revenue restructuring and a new government promising an increase in spending on tax enforcement, what more could happen in a year?

  • Still at a standstill?

    Transfer pricing is on the radar again in the Philippines, reports Maria Carmela Peralta of KPMG. It’s too early to tell whether the lengthy discussions taking place will bear fruit and the Philippines will have something other to show than its 2013 TP regulations, which the Philippine Bureau of Internal Revenue (BIR) is perceived to have overlooked.

  • Fine-tuning the legislation for greater compliance

    Singapore has been increasing its focus on transfer pricing, explain Geoffrey K Soh, Felicia Chia and Jingyi Lee of KPMG, with yearly revisions of the TP guidelines as well as the adoption of country-by-country reporting requirements. Recently, there has been a greater-than-ever push to ensure that taxpayers’ profitability is consistent with the economic activities conducted and value generated.

  • Head start for new developments

    Transfer pricing rules were introduced in Sri Lanka in 2006 and became enforceable from 2008, writes Shamila Jayasekara of KPMG. The revenue authorities did not administratively enforce the rules, giving time for taxpayers to conform to requirements.

  • Stepping in line with global trends

    To align with international tax trends, Taiwan’s Ministry of Finance (MoF) announced amendments on November 13 2017 to existing transfer pricing assessment regulations, write Sherry Chang, Karl Chan and Anita Lin of KPMG.

  • Thai transfer pricing law to be enacted in 2018

    It has been more than three years since the framework of the transfer pricing law was first drafted and approved by the Cabinet of Thailand in May 2015, write Benjamas Kullakattimas, Abhisit Pinmaneekul and Chollatip Santitorn of KPMG.

  • The reality of Decree 20

    Vietnam’s regulatory changes have required an increasing number of taxpayers having to be aware of the transfer pricing rules, explain Hoang Thuy Duong, Tran Thi Thuy Ha and Sandra Liston of KPMG. However, inconsistencies in the interpretation has led to substantial efforts by the tax authority to clarify the rules.

International Correspondents