EY Global Tax Controversy Flash Newsletter (Issue 19) | Upsurge of transfer pricing controversy seen in emerging countries

Tax administrators in emerging countries continue their efforts to prevent perceived base erosion, resulting in increased transfer pricing audits and controversy in these countries. In some Asian and Latin American countries, for example, tax authorities have been assertive in questioning what they perceive as “abusive” intercompany financing, in addition to challenging commodities transfer pricing and the substance of principal companies along the supply chain. In today’s environment, it is mor…