Transfer Pricing Enforcement in ASEAN: Institutional Capacity and Tax Justice Outcomes

Abstract

Transfer pricing enforcement remains a major challenge for tax authorities in Southeast Asia due to limited capacity and complex multinational structures. This paper compares transfer pricing enforcement practices in Indonesia, Malaysia, and Vietnam to assess their implications for tax justice. Using doctrinal analysis and institutional comparison, the study examines legal frameworks, audit practices, and dispute resolution mechanisms. The findings indicate that differences in administrative capacity significantly influence enforcement effectiveness. Countries with specialized transfer pricing units and clearer guidelines achieve more equitable outcomes. The global contribution of this study lies in demonstrating how institutional capacity shapes the realization of tax justice in developing regions. The paper contributes to global debates on strengthening transfer pricing governance by providing ASEAN-based evidence on best practices and structural constraints.