The aim of governments, international organisations and the BEPS initiative has been to create standards for transfer pricing rules. And although the basic principles have been standardized, the result is not.
Communist Vietnam and free market Hong Kong have a different take on taxes in general, and transfer pricing in particular. Another points is that most national governments have an incentive to implement regulation that affects their tax base. The fact that these countries have different economies results in a very different focus. Not many people are licensing IP from a holding company in Hanoi and Singapore doesn’t sell lots of farm products.
For these reasons, there is not a lot of uniformity within the implementation of transfer pricing regulation. Unfortunately, this makes it harder for people like you to understand what you are required to do.
On this page, we link to a number of different countries and explain their rules. Over time, we will add more and more countries to this list.
If your country is not on the list, or if you have any specific questions, please contact us.