Transfer Pricing Controversy: Trends shaping the ENR sector in APAC

This report outlines KPMG insights from the recent transfer pricing audits when KPMG assisted companies in the Energy and Natural Resources space with managing the disputes.

The Energy and Natural Resources (ENR) sector in Asia Pacific (APAC) faces escalating transfer pricing (TP) controversy due to complex supply chains, geopolitical tensions, and industry shifts toward sustainability and technology. As a result, tax authorities are intensifying audits and scrutinising the internal prices of commodities, intercompany services, financing, and use of intangibles. As a consequence, ENR businesses are operating in an environment where robust documentation, reliabl...

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Authors: Glen Hutchings

Published Date: 21 May 2026