Transfer Pricing

Transfer Pricing remains a key area of scrutiny for the Inland Revenue Board.

Transfer pricing in Malaysia refers to the pricing of transactions between related entities, such as companies within the same multinational group. Malaysia has transfer pricing regulations in place to ensure that transactions between related parties are conducted at arm’s length, meaning they are priced as if the parties were unrelated and dealing with each other independently.

The Malaysian transfer pricing regulations are primarily governed by the Income Tax Act 1967 and the Transfer Pricing Guidelines issued by the Inland Revenue Board of Malaysia (IRBM). These guidelines provide detailed instructions and methodologies for determining arm’s length prices, documentation requirements, and compliance procedures.

Our services

Transfer Pricing Policy Development

Crafting a transfer pricing policy tailored to your business needs and aligned with relevant regulations and international standards.

Transfer Pricing Documentation

Preparing comprehensive documentation to support the transfer pricing policy, including benchmarking studies, functional analyses, and economic analyses.

Risk Assessment and Compliance Review

Assessing transfer pricing risks within your organization and conducting compliance reviews to ensure adherence to transfer pricing regulations.

Advance Pricing Agreements (APAs)

Assisting in the negotiation and implementation of APAs with tax authorities to provide certainty and mitigate transfer pricing risks.

Transfer Pricing Audits and Dispute Resolution

Representing clients in transfer pricing audits and disputes with tax authorities, including responding to inquiries, providing documentation, and negotiating settlements.

Transfer Pricing Training and Education

Providing training and education sessions to help clients understand transfer pricing concepts, regulations, and compliance requirements.

Intercompany Transactions Planning

Advising on the structuring of intercompany transactions to achieve tax efficiency and compliance with transfer pricing rules.

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