With the economic fallout due to the COVID-19 pandemic, there has been an increase in transfer pricing audits as tax authorities are looking to collect additional revenues. As a result, transfer pricing adjustments made by tax authorities, including secondary adjustments, are on the rise.
In addition, tax authorities are aggressively introducing penalties for non-compliance of transfer pricing documentation. Tax authorities are also focusing on the quality of transfer pricing documentation by relying on reconstructing provisions looking at substance over form issues.
Crowe’s regional transfer pricing experts from Indonesia, Malaysia and Singapore, discuss these key developments in the area of transfer pricing audits, and how double taxation in relation to these audits can be mitigated through voluntary disclosure programs, mutual agreement procedures and advance pricing arrangements.
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