Your intercompany agreements, the lifeblood of your intra-group transactions, are under intense scrutiny. Lack of proper documentation or outdated agreements can trigger tax authorities' suspicions and lead to audits. Are your agreements arm's length, well-structured, and up-to-date with the latest regulations? Think not? You could be treading on thin ice.

Intellectual property, copyrights, and trademarks are valuable assets, but their transfer pricing can be a tangled web. Mispricing these assets can shift profits across borders, raising red flags for tax authorities. Do you have a robust methodology for valuing intangible assets? Can you demonstrate their contribution to your overall business value chain? If you're unsure, the consequences could be costly.

With increasing scrutiny, transfer pricing audits are becoming more common. Failure to comply with documentation requirements, local file preparation, and Country-by-Country reporting can lead to significant penalties. Are you confident in your documentation practices? Can you readily demonstrate the arm's length nature of your transactions? Falling short can be a costly oversight.

Remember, compliance is not just about ticking boxes. It's about building a robust transfer pricing framework that aligns with regional regulations and business realities. This includes maintaining comprehensive documentation, conducting regular reviews, and staying updated on the evolving landscape.

E-commerce, online platforms, and digital services are rapidly reshaping the Asian business landscape. But the question of how to price these digitally driven transactions within an MNE group remains a murky grey area. Traditional transfer pricing methods often stumble in this dynamic space, leaving tax authorities unsure and companies vulnerable to potential challenges.