Tax aspects of transfer pricing – The global tax system is currently based on a “separate entity” principle. Under this principle, every entity is considered a separate independent taxpayer by local tax authorities. As a result, the taxable profits of every entity within an Multinational Enterprise (MNE) group should be determined on a standalone basis. As transfer pricing is an instrument that allows profit to be shifted from one entity to another, national tax authorities are suspicious of the transfer pricing practice of MNEs and the related possibilities for manipulating taxable profits in their jurisdictions.

In conjunction with this trend, there has been an increase in transfer pricing scrutiny by the tax authorities and other governing bodies (e.g., General Department of Customs and Excise, General Department of Taxation, etc.), especially during the tax audit process. As a result, they have been strictly required to have the supporting transfer pricing documentation in place and will be imposed penalties for non-compliance. 


KPMG’s Global Transfer Pricing Services (GTPS) network comprises over 1,500 professionals from KPMG member firms around the world who work together to provide local knowledge, experience, and global analysis to assist multinational companies in addressing their transfer pricing responsibilities.

KPMG Cambodia’s dedicated transfer pricing team - which is part of KPMG’s GTPS – has extensive experience in assisting multinational companies and Cambodian companies manage their local transfer pricing risks and their local compliance requirements. KPMG’s GTPS practice includes economists, tax practitioners, and financial analysts. We use knowledge of local rules and how they interact to help member firm clients source tax efficient pricing.

What can we do for you?

KPMG’s GTPS in Cambodia can assist you with each step of your transfer pricing strategy. Our Transfer Pricing advisory services include:

  • Prepare/Update/Review transfer pricing documentation
  • TP health check
  • TP audit support
  • TP advisory services

Our KPMG Transfer Pricing in Cambodia brochure is available to download now!


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