Mongolia Transfer Pricing Documentation Requirements
Mongolia requires a Master File and Local File from taxpayers above a MNT 6 billion sales threshold and from foreign-invested companies, with a penalty geared to the value of the related-party transactions. An annual transfer pricing transactional report is due by 10 February following year-end.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Annual sales > MNT 6bn (standalone or group), or a foreign-invested company | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | MN | Yes (3% of total related-party transactions) |
Local File Required | Same thresholds as the Master File | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | MN | Yes (3% of total related-party transactions) |
TP transactional report Annual filing | All taxpayers with related-party transactions | By 10 February following year-end | Submission deadline The documentation must be filed with the tax authority by the date shown. | MN | Yes |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Mongolia deadline
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Scope of the documentation obligation
A taxpayer must submit a Master File and Local File where any of three conditions is met: annual sales income above MNT 6 billion on standalone financial statements, group annual sales income above MNT 6 billion on consolidated statements, or status as a foreign-invested company, broadly an entity with at least 25 percent foreign ownership under the investment law. The documentation is held available by the return filing date, and all taxpayers must additionally provide an annual transfer pricing transactional report by 10 February following the year-end.
Distinctive features of the Mongolian regime
Two features distinguish the Mongolian regime. The first is the foreign-investment trigger: a foreign-invested company is brought within the Master File and Local File requirement on the basis of its ownership, independently of its sales level, which captures inbound investment structures that might otherwise fall below the financial threshold. The second is the value-based penalty, set at 3 percent of the total related-party transactions, both local and cross-border, where a file is not submitted within the deadline, in addition to tax arrears. The annual transactional report due by 10 February is a separate, universal filing for all taxpayers with related-party dealings. There is no published safe harbour.
Benchmarking and comparables
Local comparables are preferable in the first instance, and where local comparables are unavailable pan-Asia-Pacific comparables may be applied. Both single-year and multi-year analyses are acceptable. A fresh benchmarking search is required every year. The general limitation period for tax purposes, including transfer pricing, is four years.
Frequently asked questions
Why might a foreign-invested company in Mongolia need documentation regardless of its sales?
A foreign-invested company, broadly one with at least 25 percent foreign ownership, is brought within the Master File and Local File requirement on the basis of its ownership, independently of whether it meets the MNT 6 billion sales threshold.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.